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 - unexplained cash credit - if the AO wanted to disbelieve the identity, credit-worthiness and genuineness of transaction of cash depositors with the assessee, the AO’s could have carried out more enquiry by examining these persons to establish whether they have given cash to the assessee for carrying out share trading on their behalf or not - Additions deleted.
Addition u/s 68 - unexplained cash credit - if the AO wanted to disbelieve the identity, credit-worthiness and genuineness of transaction of cash depositors with the assessee, the AO’s could have carried out more enquiry by examining these persons to establish whether they have given cash to the assessee for carrying out share trading on their behalf or not - Additions deleted.
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