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 unexplained investments u/s 69B - alleged cash payment for purchase of land - alleged purchase value noted in the diary found in search - it does not contain any information as to what was the cheque amount or cash amount and what was the date of the transaction - on record is a mere noting of the diary which in the absence of any other corroborative evidence cannot be utilized for making addition
Addition of unexplained investments u/s 69B - alleged cash payment for purchase of land - alleged purchase value noted in the diary found in search - it does not contain any information as to what was the cheque amount or cash amount and what was the date of the transaction - on record is a mere noting of the diary which in the absence of any other corroborative evidence cannot be utilized for making addition
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