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...
Reopening of assessment u/s 147 - Sham transaction - accommodation entries - during the search directors of the company admitted of providing accommodation entry, which statement was not denied by the assessee except by making a bald statement that the statement given by the directors are general in nature. The ld. CIT(A) has made detailed analysis of the material available on record and justified the action of the AO in making the impugned order. - AT
Reopening of assessment u/s 147 - Sham transaction - accommodation entries - during the search directors of the company admitted of providing accommodation entry, which statement was not denied by the assessee except by making a bald statement that the statement given by the directors are general in nature. The ld. CIT(A) has made detailed analysis of the material available on record and justified the action of the AO in making the impugned order. - AT
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