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...
Excess stock found during the course of survey - unexplained investments u/s 69 r.w.s.115BBE - The ITAT concluded that the addition made by the AO was not justified. They noted that the assessee had reconciled the differences in stock with supporting evidence, and neither the AO nor the CIT(A) had pointed out any defects or discrepancies in the reconciliation. - The Tribunal held that mere existence of differences in stock during a survey does not warrant automatic additions if the assessee has reconciled the differences with supporting evidence.
Excess stock found during the course of survey - unexplained investments u/s 69 r.w.s.115BBE - The ITAT concluded that the addition made by the AO was not justified. They noted that the assessee had reconciled the differences in stock with supporting evidence, and neither the AO nor the CIT(A) had pointed out any defects or discrepancies in the reconciliation. - The Tribunal held that mere existence of differences in stock during a survey does not warrant automatic additions if the assessee has reconciled the differences with supporting evidence.
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