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...
Unexplained expenditure - certain entries were found unmatched / not accounted for in the books of accounts in the expense ledger of the assessee - The assessee contended that the expenses were accounted for but not individually, and were incurred by employees at respective sites, later reimbursed by the assessee. However, the Tribunal (ITAT) found the explanation insufficient, emphasizing the need for proper documentation and evidence. While partially allowing the appeal, the tribunal imposed a restricted disallowance of 25% of the amount determined by the AO.
Unexplained expenditure - certain entries were found unmatched / not accounted for in the books of accounts in the expense ledger of the assessee - The assessee contended that the expenses were accounted for but not individually, and were incurred by employees at respective sites, later reimbursed by the assessee. However, the Tribunal (ITAT) found the explanation insufficient, emphasizing the need for proper documentation and evidence. While partially allowing the appeal, the tribunal imposed a restricted disallowance of 25% of the amount determined by the AO.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
