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...
Bogus loans u/s 68 - unsecured loans from the three loan creditors and interest on loans - reliance on third party statement - The ITAT upheld the CIT(A)'s order, stating that the assessee had discharged its burden by submitting the requisite information, and the onus lies on the AO to make enquiries. The AO failed to make further enquiries and relied on the statement recorded, which was retracted subsequently. - AT
Bogus loans u/s 68 - unsecured loans from the three loan creditors and interest on loans - reliance on third party statement - The ITAT upheld the CIT(A)'s order, stating that the assessee had discharged its burden by submitting the requisite information, and the onus lies on the AO to make enquiries. The AO failed to make further enquiries and relied on the statement recorded, which was retracted subsequently. - AT
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