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...
Uncorroborated WhatsApp chats, incomplete promissory-note images and vague seized notings were treated as insufficient to sustain additions for undisclosed income where no cash trail, confirmations, statements or other primary evidence was produced. Proposed land and flat deals that never materialised could not support investment or on-money additions, and notional interest could not be taxed again where the same income had already been assessed elsewhere. Brokerage arising from intermediary real estate transactions was treated as business income and restricted to 2%, while telescoping of source and application was directed on verification. Jewellery found in a locker was also accepted within the prescribed household limits.
Uncorroborated WhatsApp chats, incomplete promissory-note images and vague seized notings were treated as insufficient to sustain additions for undisclosed income where no cash trail, confirmations, statements or other primary evidence was produced. Proposed land and flat deals that never materialised could not support investment or on-money additions, and notional interest could not be taxed again where the same income had already been assessed elsewhere. Brokerage arising from intermediary real estate transactions was treated as business income and restricted to 2%, while telescoping of source and application was directed on verification. Jewellery found in a locker was also accepted within the prescribed household limits.
Note: It is a system-generated summary and is for quick reference only.
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