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 share transactions - Reliance on the statement of broker/entry operator - the denial of opportunity for cross-examination by the Assessing Officer was a failure of the principles of natural justice and thus the evidence used against the assessee was discarded. The Tribunal also recognized the assessee's documentation supporting the transactions, including ledger accounts, purchase and sale bills, and bank statements. - AT
Bogus share transactions - Reliance on the statement of broker/entry operator - the denial of opportunity for cross-examination by the Assessing Officer was a failure of the principles of natural justice and thus the evidence used against the assessee was discarded. The Tribunal also recognized the assessee's documentation supporting the transactions, including ledger accounts, purchase and sale bills, and bank statements. - AT
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