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 u/s 68 - onus to prove the identity, creditworthiness and genuineness of the share applicants - Both the nature & source of the share application received was fully explained by the assessee. The assessee had discharged its onus to prove the identity, creditworthiness and genuineness of the share applicants. - the addition made by the AO and sustained by Ld CIT(A) was based on conjectures and surmises, so it cannot be justified - AT
Addition u/s 68 - onus to prove the identity, creditworthiness and genuineness of the share applicants - Both the nature & source of the share application received was fully explained by the assessee. The assessee had discharged its onus to prove the identity, creditworthiness and genuineness of the share applicants. - the addition made by the AO and sustained by Ld CIT(A) was based on conjectures and surmises, so it cannot be justified - AT
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