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...
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Undisclosed income - since the advances made to boat owners was subject to tax out of which fish was supplied and Same was sold and the sale proceeds was shown as receivables from debtors. Allowing relief to the assessee as bad debts / business loss out of advances given to the boat owners is a separate issue. It is because of certain advances given to the boat owners was allowed as business loss, that cannot lead to the conclusion that the entire amount of unaccounted sales is to be taxed. - AT
Undisclosed income - since the advances made to boat owners was subject to tax out of which fish was supplied and Same was sold and the sale proceeds was shown as receivables from debtors. Allowing relief to the assessee as bad debts / business loss out of advances given to the boat owners is a separate issue. It is because of certain advances given to the boat owners was allowed as business loss, that cannot lead to the conclusion that the entire amount of unaccounted sales is to be taxed. - AT
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