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 notes that unaccounted sales should be taxed only to the extent of net profit embedded in those sales where seized material reflects both direct costs and indirect expenses; taxing the full gross profit element is excessive, and the rate in this matter was fixed at 2%. It also states that cash found during search can be telescoped against income already sustained on estimate where no separate use of that income elsewhere is shown, so a separate unexplained-money addition is deleted. Further, where profit estimation already subsumes the expenditure of the unaccounted activity, a separate addition for unexplained expenditure under section 69C would amount to double addition and should not survive.
ITAT notes that unaccounted sales should be taxed only to the extent of net profit embedded in those sales where seized material reflects both direct costs and indirect expenses; taxing the full gross profit element is excessive, and the rate in this matter was fixed at 2%. It also states that cash found during search can be telescoped against income already sustained on estimate where no separate use of that income elsewhere is shown, so a separate unexplained-money addition is deleted. Further, where profit estimation already subsumes the expenditure of the unaccounted activity, a separate addition for unexplained expenditure under section 69C would amount to double addition and should not survive.
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