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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...
A belated challenge to the Assessing Officer's jurisdiction failed because no objection was raised during assessment or before completion of the assessment, and the point was first taken only as an additional ground; the tribunal therefore treated the objection as barred by the statutory time limit. The addition for unexplained money was also sustained because the cash book did not evidence availability of cash on the date of seizure, with no entries for the intervening period and no support for the claim that the cash belonged to the firm or had been withdrawn for purchases. The appeal was dismissed.
A belated challenge to the Assessing Officer's jurisdiction failed because no objection was raised during assessment or before completion of the assessment, and the point was first taken only as an additional ground; the tribunal therefore treated the objection as barred by the statutory time limit. The addition for unexplained money was also sustained because the cash book did not evidence availability of cash on the date of seizure, with no entries for the intervening period and no support for the claim that the cash belonged to the firm or had been withdrawn for purchases. The appeal was dismissed.
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