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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Unexplained investment - Primary onus - The assessee has deposited cash in its ICICI Bank account on various occasions, and onus is very heavy on assessee to explain these cash deposits. It is for the assessee to substantiate its state of affairs and income which is chargeable to tax. If the assessee fails to discharge its primary onus, then Revenue has all the right to bring to tax unexplained credits, money as well investments - AT
Unexplained investment - Primary onus - The assessee has deposited cash in its ICICI Bank account on various occasions, and onus is very heavy on assessee to explain these cash deposits. It is for the assessee to substantiate its state of affairs and income which is chargeable to tax. If the assessee fails to discharge its primary onus, then Revenue has all the right to bring to tax unexplained credits, money as well investments - AT
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