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...
Cash deposits during demonetisation were accepted as explained where recorded sales, stock details, VAT returns and cash-in-hand records supported the books; the estimated gross profit addition failed because the books were rejected without specific defects, and the material showed stock-backed sales rather than suspicion. The Tribunal also held that M/s. Jain Bullion belonged to its proprietor, not the assessee, since the relevant bank accounts were operated by the proprietor and the concern had separately conducted business and filed returns. Separately, the notional annual letting value addition in search assessment was deleted because no incriminating material for that item was found during the search.
Cash deposits during demonetisation were accepted as explained where recorded sales, stock details, VAT returns and cash-in-hand records supported the books; the estimated gross profit addition failed because the books were rejected without specific defects, and the material showed stock-backed sales rather than suspicion. The Tribunal also held that M/s. Jain Bullion belonged to its proprietor, not the assessee, since the relevant bank accounts were operated by the proprietor and the concern had separately conducted business and filed returns. Separately, the notional annual letting value addition in search assessment was deleted because no incriminating material for that item was found during the search.
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