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...
Revision u/s 263 - unexplained cash deposits - onus to prove - The Pr. CIT found the assessment order erroneous and prejudicial to the revenue's interests due to inadequate verification. - The Tribunal upheld the Ld. Principal Commissioner's decision, stating that the AO had not adequately examined the sources of cash deposits nor obtained relevant details or evidence before accepting explanations. The appellant failed to provide documentary evidence supporting claims, and the AO's assessment lacked thorough inquiry.
Revision u/s 263 - unexplained cash deposits - onus to prove - The Pr. CIT found the assessment order erroneous and prejudicial to the revenue's interests due to inadequate verification. - The Tribunal upheld the Ld. Principal Commissioner's decision, stating that the AO had not adequately examined the sources of cash deposits nor obtained relevant details or evidence before accepting explanations. The appellant failed to provide documentary evidence supporting claims, and the AO's assessment lacked thorough inquiry.
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