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...
ITAT remanded the addition for alleged bogus purchases because the authorities had not first verified whether the disputed purchases were actually debited to the trading account or claimed as deduction; if they were not so claimed, the addition could not survive. The Tribunal also directed verification of the assessee's claim that genuine purchases from four parties existed and that the disputed amount had been reversed in the books. In contrast, a 50% disallowance of labour charges was sustained because the assessee produced only ledger entries and cash vouchers, without reliable evidence of the labourers' identity or other credible proof of expenditure.
ITAT remanded the addition for alleged bogus purchases because the authorities had not first verified whether the disputed purchases were actually debited to the trading account or claimed as deduction; if they were not so claimed, the addition could not survive. The Tribunal also directed verification of the assessee's claim that genuine purchases from four parties existed and that the disputed amount had been reversed in the books. In contrast, a 50% disallowance of labour charges was sustained because the assessee produced only ledger entries and cash vouchers, without reliable evidence of the labourers' identity or other credible proof of expenditure.
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