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...
Unexplained cash credit u/s 68 - bogus share capital/share premium - The tribunal noted that the appellant's company had witnessed significant growth over the years, leading to a substantial increase in the value of its shares. The ITAT also considered the financial status of the share subscribers, who demonstrated ample net worth to justify their investments. - Furthermore, the ITAT emphasized that the provisions of Section 56(2)(viib) of the Act, relating to the valuation of shares, were not applicable to the assessment year in question. It was concluded that the addition of the unexplained cash credit was unjustified.
Unexplained cash credit u/s 68 - bogus share capital/share premium - The tribunal noted that the appellant's company had witnessed significant growth over the years, leading to a substantial increase in the value of its shares. The ITAT also considered the financial status of the share subscribers, who demonstrated ample net worth to justify their investments. - Furthermore, the ITAT emphasized that the provisions of Section 56(2)(viib) of the Act, relating to the valuation of shares, were not applicable to the assessment year in question. It was concluded that the addition of the unexplained cash credit was unjustified.
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