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 opening capital as unexplained investment u/s 69 - income from undisclosed sources - The Tribunal held that for such an addition to be justified, the Assessing Officer must provide a concrete rationale for not accepting the disclosed sources of income, which was not done in this case. This decision reinforces the principle that tax authorities must adhere to strict standards of evidence and rationale when alleging undisclosed income.
Addition of opening capital as unexplained investment u/s 69 - income from undisclosed sources - The Tribunal held that for such an addition to be justified, the Assessing Officer must provide a concrete rationale for not accepting the disclosed sources of income, which was not done in this case. This decision reinforces the principle that tax authorities must adhere to strict standards of evidence and rationale when alleging undisclosed income.
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