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 made u/s. 69/69B - difference between the stamp duty value and the sale consideration with respect to purchase of property - family settlement to constitute "transfer" or not - The Tribunal found that the addition under section 69 was incorrect as the investment was recorded in the books. For section 69B, the AO failed to provide evidence that the assessee expended more than recorded. The Tribunal also noted that section 56(2)(vii)(b) was not applicable to companies and section 56(2)(x) was effective from AY 2017-18. The Tribunal concluded that the transaction under family settlement did not amount to a "transfer" and deleted the addition.
Addition made u/s. 69/69B - difference between the stamp duty value and the sale consideration with respect to purchase of property - family settlement to constitute "transfer" or not - The Tribunal found that the addition under section 69 was incorrect as the investment was recorded in the books. For section 69B, the AO failed to provide evidence that the assessee expended more than recorded. The Tribunal also noted that section 56(2)(vii)(b) was not applicable to companies and section 56(2)(x) was effective from AY 2017-18. The Tribunal concluded that the transaction under family settlement did not amount to a "transfer" and deleted the addition.
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