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 - unexplained cash credit - The tribunal noted that the transactions were conducted through banking channels, and the assessee had provided all necessary documentation, including the identity and financial status of the investor company. The decision emphasized that suspicion, however strong, cannot substitute for proof and that the genuineness of the transactions was adequately established by the assessee.
Addition u/s 68 - unexplained cash credit - The tribunal noted that the transactions were conducted through banking channels, and the assessee had provided all necessary documentation, including the identity and financial status of the investor company. The decision emphasized that suspicion, however strong, cannot substitute for proof and that the genuineness of the transactions was adequately established by the assessee.
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