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...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Omission of clause (i) of section 92BA was treated as having retrospective effect, so the reference to the TPO and the transfer pricing adjustment based on specified domestic transactions was held invalid and deleted. Brokerage paid in the ordinary course of a leasing business was allowed under section 37(1) to the extent supported by invoices and tenant details, while the balance was remitted for verification. Receipts such as car parking income, interest on fixed deposits, permission charges and licence fee were held to have a direct nexus with SEZ business and were treated as eligible for deduction under section 80IAB, making their reclassification as income from other sources unsustainable.
Omission of clause (i) of section 92BA was treated as having retrospective effect, so the reference to the TPO and the transfer pricing adjustment based on specified domestic transactions was held invalid and deleted. Brokerage paid in the ordinary course of a leasing business was allowed under section 37(1) to the extent supported by invoices and tenant details, while the balance was remitted for verification. Receipts such as car parking income, interest on fixed deposits, permission charges and licence fee were held to have a direct nexus with SEZ business and were treated as eligible for deduction under section 80IAB, making their reclassification as income from other sources unsustainable.
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