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...
Unexplained cash deposits during demonetization period - Assessee could not also explain how the amount withdrawn in the year 2013 was made available for depositing in the year 2016, that too during demonetization period. The arguments of the assessee that money was kept for the purpose of treatment of his brother was also unproved, because no evidence has been filed to justify his arguments and further, there was no proof as to how much was spent for treatment and how much balance was available with the assessee. - AT
Unexplained cash deposits during demonetization period - Assessee could not also explain how the amount withdrawn in the year 2013 was made available for depositing in the year 2016, that too during demonetization period. The arguments of the assessee that money was kept for the purpose of treatment of his brother was also unproved, because no evidence has been filed to justify his arguments and further, there was no proof as to how much was spent for treatment and how much balance was available with the assessee. - AT
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