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...
Unexplained investment u/s 69 - The tribunal closely examined the additions made under Section 69 related to unexplained investments in stock. The assessees argued that rough jottings or documents seized during raids were not conclusive evidence of unaccounted investments. Furthermore, they contended that previous voluntary disclosures or surrendered amounts during surveys should offset these additions.
Unexplained investment u/s 69 - The tribunal closely examined the additions made under Section 69 related to unexplained investments in stock. The assessees argued that rough jottings or documents seized during raids were not conclusive evidence of unaccounted investments. Furthermore, they contended that previous voluntary disclosures or surrendered amounts during surveys should offset these additions.
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