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 - We do not understand proposition of the assessee that cash had changed the hands from the company to its promoter–Director without any reason and there is no reason forthcoming as to why the cash was paid in cash by the three parties. There is no document produced before either the AO or before CIT (Appeals) or before us to prove the genuineness of the transaction. - While deleting the addition the CIT (Appeals) has not discussed about the proving of genuineness of the transaction by the assessee. - Matter restored back - AT
Addition u/s 68 - We do not understand proposition of the assessee that cash had changed the hands from the company to its promoter–Director without any reason and there is no reason forthcoming as to why the cash was paid in cash by the three parties. There is no document produced before either the AO or before CIT (Appeals) or before us to prove the genuineness of the transaction. - While deleting the addition the CIT (Appeals) has not discussed about the proving of genuineness of the transaction by the assessee. - Matter restored back - AT
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