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...
Inclusion of an amount on the basis of Form 26AS to the returned income of the assessee - The assessee who had denied ownership of the aforesaid income or the source thereof, we are of the considered view that the A.O was not justified in adding the impugned amount as the income of the assessee. Multiple reasons leading to the aforesaid anomaly in reflection of the above mentioned amount in the annual tax statement of the assessee cannot be ruled out. - AT
Inclusion of an amount on the basis of Form 26AS to the returned income of the assessee - The assessee who had denied ownership of the aforesaid income or the source thereof, we are of the considered view that the A.O was not justified in adding the impugned amount as the income of the assessee. Multiple reasons leading to the aforesaid anomaly in reflection of the above mentioned amount in the annual tax statement of the assessee cannot be ruled out. - AT
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