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...
Penalty u/sec. 271(1)(c) - income disclosed in search action - Ex-parte order - The Tribunal observed that the assessee admitted to suppressed receipts, which were disclosed only after a search action and subsequent to the statement recorded under Section 132(4) of the Act. - The disclosure of suppressed receipts in the return filed under Section 153A of the Act did not absolve the assessee from penalty, as per legal precedent.
Penalty u/sec. 271(1)(c) - income disclosed in search action - Ex-parte order - The Tribunal observed that the assessee admitted to suppressed receipts, which were disclosed only after a search action and subsequent to the statement recorded under Section 132(4) of the Act. - The disclosure of suppressed receipts in the return filed under Section 153A of the Act did not absolve the assessee from penalty, as per legal precedent.
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