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...
Section 69C concerns whether the source of expenditure remains unexplained, not merely whether underlying purchases are alleged to be bogus. Documentary support for transactions and bank disbursements upon encashment of letters of credit may explain the funding source. Allegations that goods did not move or documents were forged require independent inquiry, verification, examination of beneficiary entities, or other cogent material. Where sales are accepted, an addition made under section 69C cannot be sustained by recasting it under a different provision. The discussion also addresses consequential taxation under section 115BBE.
Section 69C concerns whether the source of expenditure remains unexplained, not merely whether underlying purchases are alleged to be bogus. Documentary support for transactions and bank disbursements upon encashment of letters of credit may explain the funding source. Allegations that goods did not move or documents were forged require independent inquiry, verification, examination of beneficiary entities, or other cogent material. Where sales are accepted, an addition made under section 69C cannot be sustained by recasting it under a different provision. The discussion also addresses consequential taxation under section 115BBE.
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