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. 56(2)(vii) - difference between the stamp duty guideline value and purchase consideration i.e. 50 percent u/s 56(2)(vii)(b) - the Department cannot be allowed a second inning by sending the matter back to the Assessing Officer enabling the revenue to fill the lacunae and shortcomings and further putting the assessee to face a re-trail for no fault of him and to prove before the Assessing Officer that the sale consideration was the fair market value of the property purchased by him - We delete the addition made by the AO u/s. 56(2)(vii)(b) of the Act. - AT
Addition u/s. 56(2)(vii) - difference between the stamp duty guideline value and purchase consideration i.e. 50 percent u/s 56(2)(vii)(b) - the Department cannot be allowed a second inning by sending the matter back to the Assessing Officer enabling the revenue to fill the lacunae and shortcomings and further putting the assessee to face a re-trail for no fault of him and to prove before the Assessing Officer that the sale consideration was the fair market value of the property purchased by him - We delete the addition made by the AO u/s. 56(2)(vii)(b) of the Act. - AT
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