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...
Unexplained investment - Tax value of certain assets received by it free of cost under Section 28(iv) - Therefore, the addition u/s. 69 of the Act cannot be sustained. - The entire value of assets has to be regarded as an addition made u/s. 28(1)(iv) of the Act, as was done by the AO - However the same would be eligible for deduction u/s 10A
Unexplained investment - Tax value of certain assets received by it free of cost under Section 28(iv) - Therefore, the addition u/s. 69 of the Act cannot be sustained. - The entire value of assets has to be regarded as an addition made u/s. 28(1)(iv) of the Act, as was done by the AO - However the same would be eligible for deduction u/s 10A
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