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selecting the most appropriate method does not depend on whether the assessee is loss / profit making and that in the absence of an external comparable relative contribution of each entity based on key value drivers was to be determined Infogain. It is a resident of the said country. Hewlett Packard India Software Operation Pvt Ltd v acit IT(TP)A 1682 / Bang / 2012) TS-433-itat-2015 (Bang). Adjust the variables to see how the changes affect your savings goal 403(b) Planner, if you are an employee of a non-profit organization, calculate how much of your income you should defer through your organization's 403(b) plan to prepare for retirement. Offshore supply and offshore services and onshore supply and onshore services. Appellant herein is a company incorporated in Japan. Reliable Cashew Co (P) Ltd v acit (I.T.A.
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Dharmapuri Paper Mills Pvt Ltd v jcit Tax Case (Appeal) No 933 of 2005 TS-502-HC-2015 (MAD) Penalty 281. Coperion Ideal Pvt Ltd v CIT (2015) el HC 237. It held that the AO was to establish through positive evidences that the assessee and its related party had arranged their transactions to produce extra-ordinary profits. The Tribunal held that the profits of the assessee from operation of ships was not taxable in India as per Article 8 of the India-UAE dtaa. In Commissioner of Income-Tax. The Court held that service tax is not an amount paid or payable or received or deemed to be received by the assessee for the services provided by it and that the assessee was only collecting the service tax for passing it on to the. It was held : "The substance of the protocol"d above, represents the consensus reached between the parties to the treaty in regard to the meaning of the phrase "directly or indirectly attributable to that permanent establishment" employed in paragraph 1 of article. ST Microelectronics Pvt Ltd v dcit IT(TP)A No 1394 / Bang / 2014 TS-358-itat-2015(Bang)-TP. The Court held that where the AO had merely re-examined the records already available and it could not be inferred from facts on record that the assessee had not made a full and true disclosure of the material particulars necessary for assessment then the re-opening.
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