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...
The assessee claimed the entire cash amount recovered from two lockers as business income, not subject to tax u/s 115BBE. The Tribunal held that since the cash from one locker was recorded in books and the source of income from the other locker was not disputed, both amounts should be treated as business income under normal provisions, not taxed u/s 69A read with Section 115BBE dealing with unexplained cash credits. The application of Section 115BBE was found to be not legal in this case.
The assessee claimed the entire cash amount recovered from two lockers as business income, not subject to tax u/s 115BBE. The Tribunal held that since the cash from one locker was recorded in books and the source of income from the other locker was not disputed, both amounts should be treated as business income under normal provisions, not taxed u/s 69A read with Section 115BBE dealing with unexplained cash credits. The application of Section 115BBE was found to be not legal in this case.
Note: It is a system-generated summary and is for quick reference only.