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...
Bogus loss from trading in shares/securities - ITAT observed that, despite the appellant's submission of evidences during the assessment proceedings, the assessing officer did not conduct any inquiry or investigation and solely relied on the statement of the director of the appellant company, recorded during a summon under section 131 of the Act. However, this statement was retracted by filing an affidavit, highlighting its lack of evidentiary value without corroborative evidence. - Consequently, the Tribunal allowed the appeal, directing the assessing officer to delete the addition on account of the rejection of loss.
Bogus loss from trading in shares/securities - ITAT observed that, despite the appellant's submission of evidences during the assessment proceedings, the assessing officer did not conduct any inquiry or investigation and solely relied on the statement of the director of the appellant company, recorded during a summon under section 131 of the Act. However, this statement was retracted by filing an affidavit, highlighting its lack of evidentiary value without corroborative evidence. - Consequently, the Tribunal allowed the appeal, directing the assessing officer to delete the addition on account of the rejection of loss.
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