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 69A - valuable article - ambit of the word ‘owner’ in section 69A - carriage contractor for bitumen - short delivery of bitumen - Can a thief become the owner - Deemed ownership - an ‘article’ shall be considered ‘valuable’ if the concerned article is a high-priced article commanding a premium price. - AO acted illegally in holding that one appellant was the ‘owner’ and on the said basis made the addition - SC
Addition u/s 69A - valuable article - ambit of the word ‘owner’ in section 69A - carriage contractor for bitumen - short delivery of bitumen - Can a thief become the owner - Deemed ownership - an ‘article’ shall be considered ‘valuable’ if the concerned article is a high-priced article commanding a premium price. - AO acted illegally in holding that one appellant was the ‘owner’ and on the said basis made the addition - SC
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