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 68 - unexplained share application money - The Tribunal noted that the assessee provided complete details of the share subscribers, their financial capacity, and the transactions were carried out through banking channels, shifting the burden of proof to the Assessing Officer (AO) who failed to conduct an adequate inquiry to disprove the assessee's claims. Therefore, the primary onus placed on the assessee by section 68 was discharged, and the addition made by the AO was not justified.
Addition u/s 68 - unexplained share application money - The Tribunal noted that the assessee provided complete details of the share subscribers, their financial capacity, and the transactions were carried out through banking channels, shifting the burden of proof to the Assessing Officer (AO) who failed to conduct an adequate inquiry to disprove the assessee's claims. Therefore, the primary onus placed on the assessee by section 68 was discharged, and the addition made by the AO was not justified.
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