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 u/s 68 - bogus LTCG - share capital and share premium were merely paper credit entries - receipt of accommodation entries in lieu of commission paid - The Tribunal found that the amounts received by BCPL were passed through various entities without actual business transactions, acting merely as accommodation entries. It was determined that these funds should not be treated as income of BCPL. Instead, only the commission income received for facilitating these transactions should be taxed.
Addition u/s 68 - bogus LTCG - share capital and share premium were merely paper credit entries - receipt of accommodation entries in lieu of commission paid - The Tribunal found that the amounts received by BCPL were passed through various entities without actual business transactions, acting merely as accommodation entries. It was determined that these funds should not be treated as income of BCPL. Instead, only the commission income received for facilitating these transactions should be taxed.
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