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-credit additions for unexplained deposits require a comprehensive examination of the taxpayer's cash-collection business model, debtor-recovery cycle, and supporting records, including debtor ledgers, subscription records, cash books and bank statements. Where such evidence has not been fully considered, the addition requires fresh adjudication after reasonable hearing, without deciding the merits or the validity of book rejection. Interest for advance-tax default is consequential to the assessment. Penalty proceedings for unexplained or under-reported income remain separate from quantum proceedings, making a challenge to their initiation premature.
Cash-credit additions for unexplained deposits require a comprehensive examination of the taxpayer's cash-collection business model, debtor-recovery cycle, and supporting records, including debtor ledgers, subscription records, cash books and bank statements. Where such evidence has not been fully considered, the addition requires fresh adjudication after reasonable hearing, without deciding the merits or the validity of book rejection. Interest for advance-tax default is consequential to the assessment. Penalty proceedings for unexplained or under-reported income remain separate from quantum proceedings, making a challenge to their initiation premature.
Note: It is a system-generated summary and is for quick reference only.
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