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...
Addition u/s 69A - unsecured loans - interest expenditure - The case involved disputes over the addition of unsecured loans under section 69A and the disallowance of interest expenses. The assessee provided adequate documentation to prove the genuineness of the loans and the business purpose of interest payments. Consequently, both additions made by the assessing officer were overturned, and the appeal of the assessee was allowed by the appellate tribunal.
Addition u/s 69A - unsecured loans - interest expenditure - The case involved disputes over the addition of unsecured loans under section 69A and the disallowance of interest expenses. The assessee provided adequate documentation to prove the genuineness of the loans and the business purpose of interest payments. Consequently, both additions made by the assessing officer were overturned, and the appeal of the assessee was allowed by the appellate tribunal.
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