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...
Telescoping of commission income already offered was confined to the net income returned and not to the gross profit claimed, where the assessee's business transactions were found to be bogus and commission income was to be estimated on the reported turnover and fresh investments. The recomputation was directed on that basis after reducing the income already declared. Cash deposits during the demonetisation period were held explained by earlier cash withdrawals, supported by date-wise details, bank statements and books of account, so the unexplained-money addition was deleted. Self-assessment tax credit reflected in Form 26AS was directed to be allowed after verification by the AO.
Telescoping of commission income already offered was confined to the net income returned and not to the gross profit claimed, where the assessee's business transactions were found to be bogus and commission income was to be estimated on the reported turnover and fresh investments. The recomputation was directed on that basis after reducing the income already declared. Cash deposits during the demonetisation period were held explained by earlier cash withdrawals, supported by date-wise details, bank statements and books of account, so the unexplained-money addition was deleted. Self-assessment tax credit reflected in Form 26AS was directed to be allowed after verification by the AO.
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