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...
WhatsApp images, standing alone, were held insufficient to sustain additions for alleged cash salary and bonus payments because they did not identify the nature of the entries, and no corroborative evidence of actual cash disbursement was produced; the additions were deleted. In the stock matter, the alleged shortage during survey failed because silo stock was not properly quantified, the verification exercise was materially deficient, and later reconciliation and supporting records were not effectively examined; the consequent addition by applying a gross profit rate on presumed unaccounted sales was also deleted. The assessee's appeals were partly allowed and the Revenue's challenge failed.
WhatsApp images, standing alone, were held insufficient to sustain additions for alleged cash salary and bonus payments because they did not identify the nature of the entries, and no corroborative evidence of actual cash disbursement was produced; the additions were deleted. In the stock matter, the alleged shortage during survey failed because silo stock was not properly quantified, the verification exercise was materially deficient, and later reconciliation and supporting records were not effectively examined; the consequent addition by applying a gross profit rate on presumed unaccounted sales was also deleted. The assessee's appeals were partly allowed and the Revenue's challenge failed.
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