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...
Disallowance of interest - Loans advanced to sister concerns - The Tribunal noted that the Assessee had not appealed against the partial relief granted by the learned CIT (A). - Considering the availability of interest-free funds with the Assessee, the Tribunal upheld the decision of the learned CIT (A) to reduce the interest rate from 16% to 8%.
Disallowance of interest - Loans advanced to sister concerns - The Tribunal noted that the Assessee had not appealed against the partial relief granted by the learned CIT (A). - Considering the availability of interest-free funds with the Assessee, the Tribunal upheld the decision of the learned CIT (A) to reduce the interest rate from 16% to 8%.
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