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 ...
Offence u/s 276CC - petitioner prime facie found that the non-filing of the return was wilfull - Economic Offences - The petitioner's argument that the tax liability was covered by Tax Deducted at Source (TDS) was refuted, as the TDS amount was insufficient. - The High court emphasized the statutory presumption u/s 278E, shifting the burden onto the petitioner to prove absence of wilfulness. - High court dismissed the petitioner's appeal and directed the lower court to proceed with the proceedings, with a timeline for completion.
Offence u/s 276CC - petitioner prime facie found that the non-filing of the return was wilfull - Economic Offences - The petitioner's argument that the tax liability was covered by Tax Deducted at Source (TDS) was refuted, as the TDS amount was insufficient. - The High court emphasized the statutory presumption u/s 278E, shifting the burden onto the petitioner to prove absence of wilfulness. - High court dismissed the petitioner's appeal and directed the lower court to proceed with the proceedings, with a timeline for completion.
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