Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Penalty u/s. 271AAB - The assessees’ sole substantive grievance appears to be that the AO’s corresponding show cause notices dated 29.12.2017 (supra) had not been validly issued. We find no merit in the assessees’ stand once it has come on record that the impugned penalty has been levied @ 10% since falling in the first and foremost limb u/sec. 271AAB(1)(a)(i) to (iii) of the Act in the specified circumstances. - AT
Penalty u/s. 271AAB - The assessees’ sole substantive grievance appears to be that the AO’s corresponding show cause notices dated 29.12.2017 (supra) had not been validly issued. We find no merit in the assessees’ stand once it has come on record that the impugned penalty has been levied @ 10% since falling in the first and foremost limb u/sec. 271AAB(1)(a)(i) to (iii) of the Act in the specified circumstances. - AT
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