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...
Best judgment assessment in a civil contract business must rest on a fair estimate with nexus to available material; a flat 15 per cent profit rate was found arbitrary on the facts, and business income was directed to be recomputed at 7 per cent of turnover. The Tribunal also held that claims for Chapter VI-A deductions and credits for TDS and self-assessment tax could not be decided on the existing record because supporting documents and reconciliations were incomplete, so the matter was remitted for verification and grant of eligible relief in accordance with law.
Best judgment assessment in a civil contract business must rest on a fair estimate with nexus to available material; a flat 15 per cent profit rate was found arbitrary on the facts, and business income was directed to be recomputed at 7 per cent of turnover. The Tribunal also held that claims for Chapter VI-A deductions and credits for TDS and self-assessment tax could not be decided on the existing record because supporting documents and reconciliations were incomplete, so the matter was remitted for verification and grant of eligible relief in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
