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 ...
Determination of long term capital gain u/s 50C - The Tribunal observed that the part payment of consideration was received by the assessee prior to the execution of the agreement to sale. Furthermore, the sale consideration declared by the assessee was significantly higher than the prevailing jantri rate at the time of the agreement. Therefore, the Tribunal held that the assessee was entitled to the benefit of the first and second provisos to Section 50C.
Determination of long term capital gain u/s 50C - The Tribunal observed that the part payment of consideration was received by the assessee prior to the execution of the agreement to sale. Furthermore, the sale consideration declared by the assessee was significantly higher than the prevailing jantri rate at the time of the agreement. Therefore, the Tribunal held that the assessee was entitled to the benefit of the first and second provisos to Section 50C.
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