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...
Addition of commission expenses and franking charges - Allowable business expenditure or not? - The Tribunal acknowledged that the assessee had provided details of the commission agents to whom payments were made, along with invoices. However, it noted that certain details, such as the PAN of some agents, were missing. The Tribunal directed the AO to verify whether these agents had declared the commission income in their tax returns. If the agents could demonstrate that they declared the income, and the services provided were genuine, the commission expenses should be allowed.
Addition of commission expenses and franking charges - Allowable business expenditure or not? - The Tribunal acknowledged that the assessee had provided details of the commission agents to whom payments were made, along with invoices. However, it noted that certain details, such as the PAN of some agents, were missing. The Tribunal directed the AO to verify whether these agents had declared the commission income in their tax returns. If the agents could demonstrate that they declared the income, and the services provided were genuine, the commission expenses should be allowed.
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