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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Addition u/s 69C r.w.s.115BBE - Payment of credit card by cash as a unexplained expenditure - Without establishing conclusively, a section like 69C falling under the head Income from Other Sources and that is to, a deeming section, no adverse inference can be drawn against the assessee. We found the order of AO and Ld. CIT(A) are based on conjunction and surmises. - AT
Addition u/s 69C r.w.s.115BBE - Payment of credit card by cash as a unexplained expenditure - Without establishing conclusively, a section like 69C falling under the head Income from Other Sources and that is to, a deeming section, no adverse inference can be drawn against the assessee. We found the order of AO and Ld. CIT(A) are based on conjunction and surmises. - AT
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