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 ...
Revision u/s 263 - The ITAT held that the AO had conducted adequate inquiries into the sales promotion expenses, as evidenced by the issuance of specific queries to the assessee. The AO's decision to accept the assessee's claims was based on the responses and documents provided. The ITAT found that the PCIT's revision under Section 263, alleging non-verification of the said expenses, was not justified as the AO had made necessary inquiries and applied his mind to the information available.
Revision u/s 263 - The ITAT held that the AO had conducted adequate inquiries into the sales promotion expenses, as evidenced by the issuance of specific queries to the assessee. The AO's decision to accept the assessee's claims was based on the responses and documents provided. The ITAT found that the PCIT's revision under Section 263, alleging non-verification of the said expenses, was not justified as the AO had made necessary inquiries and applied his mind to the information available.
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