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...
Addition u/s 69C - bogus purchases of diamonds - The decision emphasizes the principle that where the genuineness of purchases is in question, but corresponding sales are not disputed, only the profit element embedded in the transactions should be brought to tax. The Tribunal's ruling aligns with the principle that in cases of alleged bogus purchases, if sales are unaffected, the focus should be on taxing the profit margin rather than disallowing entire purchases. - AT
Addition u/s 69C - bogus purchases of diamonds - The decision emphasizes the principle that where the genuineness of purchases is in question, but corresponding sales are not disputed, only the profit element embedded in the transactions should be brought to tax. The Tribunal's ruling aligns with the principle that in cases of alleged bogus purchases, if sales are unaffected, the focus should be on taxing the profit margin rather than disallowing entire purchases. - AT
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