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 cash recognised in an earlier year as exempt agricultural-land sale proceeds remains available against a later unexplained-money addition unless the Revenue establishes its intervening investment or expenditure. Cash attributed to a non-earning senior citizen mother and minor children may be explained through household savings, pin money, stridhan and customary family gifts; non-filing of returns alone does not discredit such explanations where income does not exceed the non-taxable threshold. The evaluation must account for human probabilities, surrounding circumstances and Indian socio-cultural practices rather than demand commercial records or mathematical precision. The remaining addition for unexplained money was deleted.
Telescoping of cash recognised in an earlier year as exempt agricultural-land sale proceeds remains available against a later unexplained-money addition unless the Revenue establishes its intervening investment or expenditure. Cash attributed to a non-earning senior citizen mother and minor children may be explained through household savings, pin money, stridhan and customary family gifts; non-filing of returns alone does not discredit such explanations where income does not exceed the non-taxable threshold. The evaluation must account for human probabilities, surrounding circumstances and Indian socio-cultural practices rather than demand commercial records or mathematical precision. The remaining addition for unexplained money was deleted.
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