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 of income declared by assessee under Voluntary Disclosure of Income Scheme, 1997 (VDIS, 1997’) - The Tribunal allowed the assessee's appeal and deleted the addition made by the ITD. The Tribunal noted that the assessee provided evidence to support their claim that the investments and expenditures related to previous years, and the ITD did not establish that they occurred in 1997-98.
Addition of income declared by assessee under Voluntary Disclosure of Income Scheme, 1997 (VDIS, 1997’) - The Tribunal allowed the assessee's appeal and deleted the addition made by the ITD. The Tribunal noted that the assessee provided evidence to support their claim that the investments and expenditures related to previous years, and the ITD did not establish that they occurred in 1997-98.
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