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...
Assessee's explanation for the alleged shortfall in wastage was supported by job-work records, invoices and confirmations, and the Tribunal found no factual infirmity; the rejection of books and estimated gross profit addition were therefore deleted. In reassessment, additions for contract-payment TDS default and delayed provident fund contribution could not survive once the recorded reason for reopening itself failed in appeal, because jurisdiction to sustain unrelated additions depends on survival of the original reopening ground. A donation deduction disallowance was not decided on merits, as adverse material was not furnished and cross-examination was denied; the matter was restored for fresh adjudication after due hearing.
Assessee's explanation for the alleged shortfall in wastage was supported by job-work records, invoices and confirmations, and the Tribunal found no factual infirmity; the rejection of books and estimated gross profit addition were therefore deleted. In reassessment, additions for contract-payment TDS default and delayed provident fund contribution could not survive once the recorded reason for reopening itself failed in appeal, because jurisdiction to sustain unrelated additions depends on survival of the original reopening ground. A donation deduction disallowance was not decided on merits, as adverse material was not furnished and cross-examination was denied; the matter was restored for fresh adjudication after due hearing.
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