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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...
Primary documentation establishing investor identity, creditworthiness and transaction genuineness is described as sufficient to discharge the initial burden for preference share capital credited under section 68. The notes state that additions cannot rest on suspicion where the Revenue produces no material showing that the assessee's own funds were routed back through investor entities. They further state that directors' adverse statements cannot sustain an addition when effective cross-examination is unavailable and documentary evidence remains undisplaced. On these stated facts, the preference share capital addition was deleted.
Primary documentation establishing investor identity, creditworthiness and transaction genuineness is described as sufficient to discharge the initial burden for preference share capital credited under section 68. The notes state that additions cannot rest on suspicion where the Revenue produces no material showing that the assessee's own funds were routed back through investor entities. They further state that directors' adverse statements cannot sustain an addition when effective cross-examination is unavailable and documentary evidence remains undisplaced. On these stated facts, the preference share capital addition was deleted.
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