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...
Additions u/sec 68 in respect of sale of shares and u/sec 69 in respect of estimated commission expenditure - The Tribunal, relying upon the judicial precedents, found that the appellant had substantiated the genuineness of the purchase and sale of shares through banking channels and documentation. The lack of independent inquiry or substantive evidence from the AO to refute the appellant's claims led to the decision to delete the additions made under sections 68 and 69C, thereby allowing the appeal in favor of the appellant.
Additions u/sec 68 in respect of sale of shares and u/sec 69 in respect of estimated commission expenditure - The Tribunal, relying upon the judicial precedents, found that the appellant had substantiated the genuineness of the purchase and sale of shares through banking channels and documentation. The lack of independent inquiry or substantive evidence from the AO to refute the appellant's claims led to the decision to delete the additions made under sections 68 and 69C, thereby allowing the appeal in favor of the appellant.
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