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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Revision u/s 263 - Bogus expenditure towards sub-contract payments made to persons who were previously employed in the assessee’s company as supervisors / garage in-charge for monthly salaries - The Tribunal observed that the AO did not examine payments to subcontractors during assessment proceedings. - The details of sub-contracts were not verified, and claims by the assessee were accepted without inquiry. - The ITAT found the AO's actions to be erroneous and prejudicial to revenue. - Hence, the proceedings under section 263 were rightly initiated.
Revision u/s 263 - Bogus expenditure towards sub-contract payments made to persons who were previously employed in the assessee’s company as supervisors / garage in-charge for monthly salaries - The Tribunal observed that the AO did not examine payments to subcontractors during assessment proceedings. - The details of sub-contracts were not verified, and claims by the assessee were accepted without inquiry. - The ITAT found the AO's actions to be erroneous and prejudicial to revenue. - Hence, the proceedings under section 263 were rightly initiated.
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