Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Addition u/s 68 - assessee has discharged the initial onus cast on it in terms of identity, creditworthiness and genuineness of the transaction - Genuineness accepted in investor company u/s 143(3) - no linkage which can be said to have been established by the Revenue between the assessee’s undisclosed income which is routed back in form of share capital - addition not sustainable.
Addition u/s 68 - assessee has discharged the initial onus cast on it in terms of identity, creditworthiness and genuineness of the transaction - Genuineness accepted in investor company u/s 143(3) - no linkage which can be said to have been established by the Revenue between the assessee’s undisclosed income which is routed back in form of share capital - addition not sustainable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
