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 undisclosed income u/s 69B - purchase of share from its directors and their closely held companies - nothing on record would demonstrate any exchange / flow of funds, out of books, between the assessee and the sellers - in the absence of any evidences establishing receipts & payments outside regular books of accounts, the provisions of Section 69B could not be invoked - addition deleted
Addition of undisclosed income u/s 69B - purchase of share from its directors and their closely held companies - nothing on record would demonstrate any exchange / flow of funds, out of books, between the assessee and the sellers - in the absence of any evidences establishing receipts & payments outside regular books of accounts, the provisions of Section 69B could not be invoked - addition deleted
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