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...
Addition u/s 68 - accommodation entry - additions made on the basis of retracted statements - amount received during the earlier years - assessee has furnished all the details relating to the investors/loan in order to discharge the burden placed upon it u/s 68 - The additions made by the Assessing Officer u/s 68 in all the years, in the facts and circumstances of the case, were not justified. We noticed earlier that some of the cash credits were received in the earlier year and not during the year under consideration. - AT
Addition u/s 68 - accommodation entry - additions made on the basis of retracted statements - amount received during the earlier years - assessee has furnished all the details relating to the investors/loan in order to discharge the burden placed upon it u/s 68 - The additions made by the Assessing Officer u/s 68 in all the years, in the facts and circumstances of the case, were not justified. We noticed earlier that some of the cash credits were received in the earlier year and not during the year under consideration. - AT
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