PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
TP adjustment - re-characterization of functionality rejected, agreements relied upon for APA considered. APA applicability and comparables remanded to AO/TPO for fresh determination as per Tribunal and HC precedents. Distribution segment - TNMM as MAM directed, ALP computation remanded. Books not rejected. Not DAPE of Google Ireland, payments not royalty/FTS. Section 10A deduction - recomputation as per SC and HC precedents. IT segment comparables remanded for fresh determination as per APA. No attribution of Google Ireland's profits. Section 10A eligibility for ITeS segment remanded for AO verification based on documents.
TP adjustment - re-characterization of functionality rejected, agreements relied upon for APA considered. APA applicability and comparables remanded to AO/TPO for fresh determination as per Tribunal and HC precedents. Distribution segment - TNMM as MAM directed, ALP computation remanded. Books not rejected. Not DAPE of Google Ireland, payments not royalty/FTS. Section 10A deduction - recomputation as per SC and HC precedents. IT segment comparables remanded for fresh determination as per APA. No attribution of Google Ireland's profits. Section 10A eligibility for ITeS segment remanded for AO verification based on documents.
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