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...
WhatsApp messages used to support an alleged cash transaction were held insufficient without corroboration, so the related addition was deleted. Additions based on a retracted search statement and a third-party statement were also unsustainable where the assessee sought copies of material and cross-examination, but no proper evidentiary foundation or independent enquiry was made. Income already returned and taxed in the spouse's hands could not be taxed again as the assessee's undisclosed income. For agricultural income, the Tribunal accepted documentary support and upheld only a limited estimate rather than the full addition. Additions based on presumed agricultural income of family members were likewise rejected for want of evidence.
WhatsApp messages used to support an alleged cash transaction were held insufficient without corroboration, so the related addition was deleted. Additions based on a retracted search statement and a third-party statement were also unsustainable where the assessee sought copies of material and cross-examination, but no proper evidentiary foundation or independent enquiry was made. Income already returned and taxed in the spouse's hands could not be taxed again as the assessee's undisclosed income. For agricultural income, the Tribunal accepted documentary support and upheld only a limited estimate rather than the full addition. Additions based on presumed agricultural income of family members were likewise rejected for want of evidence.
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