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...
Estimation of income - bogus purchases - case of bogus bills arranged from the entities and diamonds purchased from somewhere else at a lower cost - The ITAT noted the absence of crucial documentation, such as delivery challans, to substantiate the purchases. Consequently, the disallowance of purchases was upheld. - Considering the appellant's argument for a lower percentage of disallowance based on the profit margin accepted in other assessment years, the Tribunal decided to restrict the disallowance to 5% of the disputed purchases, consistent with previous decisions in the appellant's case.
Estimation of income - bogus purchases - case of bogus bills arranged from the entities and diamonds purchased from somewhere else at a lower cost - The ITAT noted the absence of crucial documentation, such as delivery challans, to substantiate the purchases. Consequently, the disallowance of purchases was upheld. - Considering the appellant's argument for a lower percentage of disallowance based on the profit margin accepted in other assessment years, the Tribunal decided to restrict the disallowance to 5% of the disputed purchases, consistent with previous decisions in the appellant's case.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
