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...
A scrutiny assessment challenge based on alleged non-compliance with CBDT scrutiny-selection instructions was rejected, the Tribunal following binding jurisdictional High Court precedent. The rent-related disallowance under section 40(a)(ia) was deleted to the extent tax was not deductible, including rent paid to Haryana Urban Development Authority. In the bogus purchase dispute, the Tribunal upheld partial relief and gross profit estimation at 2.37% on market-comparable reasoning, and applied the same approach to the connected unexplained expenditure issue. The estimated addition on sundry creditors was rejected because no individual credit entries were examined and the purchases stood accepted. The related-party salary disallowance under section 40A(2)(b) was also upheld as deleted on revenue-neutrality grounds.
A scrutiny assessment challenge based on alleged non-compliance with CBDT scrutiny-selection instructions was rejected, the Tribunal following binding jurisdictional High Court precedent. The rent-related disallowance under section 40(a)(ia) was deleted to the extent tax was not deductible, including rent paid to Haryana Urban Development Authority. In the bogus purchase dispute, the Tribunal upheld partial relief and gross profit estimation at 2.37% on market-comparable reasoning, and applied the same approach to the connected unexplained expenditure issue. The estimated addition on sundry creditors was rejected because no individual credit entries were examined and the purchases stood accepted. The related-party salary disallowance under section 40A(2)(b) was also upheld as deleted on revenue-neutrality grounds.
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