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...
Unexplained deposit of cash u/s 69A - as submitted that the source of the said sum is gift from relative which is not taxable u/s 56 - Considering the fact that undisputedly the gifts have been received from relatives as defined u/s 56(2)(vi) no dispute has been raised to the fact that father and brother of the assessee have sufficient source of income. - Additions deleted - AT
Unexplained deposit of cash u/s 69A - as submitted that the source of the said sum is gift from relative which is not taxable u/s 56 - Considering the fact that undisputedly the gifts have been received from relatives as defined u/s 56(2)(vi) no dispute has been raised to the fact that father and brother of the assessee have sufficient source of income. - Additions deleted - AT
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