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...
Admissibility of additional evidences under Rule 46A - Power of CIT(A) - Penalty u/s 271D - taking cash loan - Default under provisions of section 269SS - proof of bona fides and genuiness of the transaction - “reasonable cause” - the ld. CIT(A) has to pass a speaking order in writing as to his decision as to admission or refusal to admit additional evidences. - ld. CIT(A) did not comply with Rule 46A of the 1962 Rules. - Matter restored back - AT
Admissibility of additional evidences under Rule 46A - Power of CIT(A) - Penalty u/s 271D - taking cash loan - Default under provisions of section 269SS - proof of bona fides and genuiness of the transaction - “reasonable cause” - the ld. CIT(A) has to pass a speaking order in writing as to his decision as to admission or refusal to admit additional evidences. - ld. CIT(A) did not comply with Rule 46A of the 1962 Rules. - Matter restored back - AT
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