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...
Addition of interest income relying on 26AS - assessee claimed that interest income did not pertain to it and company has not even claimed the credit of TDS - onus will be on the AO to bring on record independent evidence after making enquiries from the payees - assessee cannot be expected to discharge the impossible burden of proving a negative
Addition of interest income relying on 26AS - assessee claimed that interest income did not pertain to it and company has not even claimed the credit of TDS - onus will be on the AO to bring on record independent evidence after making enquiries from the payees - assessee cannot be expected to discharge the impossible burden of proving a negative
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