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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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Third-party seized documents cannot, by themselves, sustain an addition where the assessee denies receipt of cash and no independent corroboration such as a cash trail or confirmation is produced; the ITAT held that the presumption under section 132(4A) read with section 292C does not operate against an assessee for material found at a third party's premises, so the addition failed. A receipt linked to a joint development agreement could not be taxed as income from other sources under section 56 without first examining whether it arose from a transfer of a capital asset and the correct year of taxability under the capital gains provisions; as the required transfer analysis was not undertaken, the addition was deleted.
Third-party seized documents cannot, by themselves, sustain an addition where the assessee denies receipt of cash and no independent corroboration such as a cash trail or confirmation is produced; the ITAT held that the presumption under section 132(4A) read with section 292C does not operate against an assessee for material found at a third party's premises, so the addition failed. A receipt linked to a joint development agreement could not be taxed as income from other sources under section 56 without first examining whether it arose from a transfer of a capital asset and the correct year of taxability under the capital gains provisions; as the required transfer analysis was not undertaken, the addition was deleted.
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