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 contract receipts - bogus activity - Estimation of income - The AO had made an addition to the assessee's income, alleging discrepancies in the contract receipts and estimating the profit at 8%. However, upon careful consideration, the Tribunal found inconsistencies in the assessment. It questioned the basis for estimating profit at 8% when the commission ranged from 0.25% to 1%, and the discrepancy regarding the actual contract receipts. The Tribunal concluded that the addition lacked demonstrative evidence and was based on surmise and conjecture.
Addition of contract receipts - bogus activity - Estimation of income - The AO had made an addition to the assessee's income, alleging discrepancies in the contract receipts and estimating the profit at 8%. However, upon careful consideration, the Tribunal found inconsistencies in the assessment. It questioned the basis for estimating profit at 8% when the commission ranged from 0.25% to 1%, and the discrepancy regarding the actual contract receipts. The Tribunal concluded that the addition lacked demonstrative evidence and was based on surmise and conjecture.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
