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...
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Administrative and establishment expenses incurred to keep a co-operative society in existence, meet statutory compliance, and preserve its affairs were held deductible against interest income on a real-income basis; the Tribunal also noted that any related business loss could be set off against income under another head. The disallowance was deleted. On self-assessment tax, the Tribunal found that credit had been given only for TDS despite payment of self-assessment tax, treated the omission as a mistake apparent from the record, and directed verification and grant of credit. The appeal was partly allowed.
Administrative and establishment expenses incurred to keep a co-operative society in existence, meet statutory compliance, and preserve its affairs were held deductible against interest income on a real-income basis; the Tribunal also noted that any related business loss could be set off against income under another head. The disallowance was deleted. On self-assessment tax, the Tribunal found that credit had been given only for TDS despite payment of self-assessment tax, treated the omission as a mistake apparent from the record, and directed verification and grant of credit. The appeal was partly allowed.
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