Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Synchronized trading used to create artificial volumes and manipulate share prices justified estimation of commission income at 5%. The Tribunal held that once the assessee's involvement in price rigging and SEBI debarment was accepted, there was no basis to treat the activity as normal brokerage or to reduce the Assessing Officer's estimate to 1%. The Commissioner (Appeals) was therefore set aside and the higher commission addition was restored.
Synchronized trading used to create artificial volumes and manipulate share prices justified estimation of commission income at 5%. The Tribunal held that once the assessee's involvement in price rigging and SEBI debarment was accepted, there was no basis to treat the activity as normal brokerage or to reduce the Assessing Officer's estimate to 1%. The Commissioner (Appeals) was therefore set aside and the higher commission addition was restored.
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