Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Addition on account of foreign currency found during the course of search - unaccounted income - The ITAT observed that no grounds to interfere with the CIT(A)'s findings. Despite acknowledging the possibility of the currency being remnants of business trips, the onus remained on the assessee to furnish conclusive evidence, which was not adequately provided. Consequently, the appeal of the assessee was dismissed.
Addition on account of foreign currency found during the course of search - unaccounted income - The ITAT observed that no grounds to interfere with the CIT(A)'s findings. Despite acknowledging the possibility of the currency being remnants of business trips, the onus remained on the assessee to furnish conclusive evidence, which was not adequately provided. Consequently, the appeal of the assessee was dismissed.
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