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 40A - genuineness commission expenses - The assessee has not produced a single document evidencing the distributorship work done by these agents. Not a single document evidencing work done by the distributors for procuring and enhancing sale of the assessee. Not even the statement showing the amounts of sales procured by these parties for the assessee from their respective regions, correlated with the accounts of the assessee, as mentioned in the agreements, has been filed - Additions confirmed - AT
Addition u/s 40A - genuineness commission expenses - The assessee has not produced a single document evidencing the distributorship work done by these agents. Not a single document evidencing work done by the distributors for procuring and enhancing sale of the assessee. Not even the statement showing the amounts of sales procured by these parties for the assessee from their respective regions, correlated with the accounts of the assessee, as mentioned in the agreements, has been filed - Additions confirmed - AT
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