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 ...
Consultancy charges paid to a sister concern were treated as genuine business expenditure because the agreements defined the work, supporting bills were on record, TDS and service tax had been deposited, and no fair market material showed the payment to be excessive; the related-party disallowance was deleted. Interest on vehicle loans was also allowed as business expenditure because the loans related to vehicles acquired in earlier years, part-year interest had been claimed previously, and the current-year increase reflected full-year interest on outstanding borrowings rather than fresh purchases; that disallowance was deleted.
Consultancy charges paid to a sister concern were treated as genuine business expenditure because the agreements defined the work, supporting bills were on record, TDS and service tax had been deposited, and no fair market material showed the payment to be excessive; the related-party disallowance was deleted. Interest on vehicle loans was also allowed as business expenditure because the loans related to vehicles acquired in earlier years, part-year interest had been claimed previously, and the current-year increase reflected full-year interest on outstanding borrowings rather than fresh purchases; that disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.