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...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Estimation of profit - AO applying a profit rate of 20% on the contract receipt against the rate of profit declared by the appellant at 8.13% - CIT(A) directing the AO to apply a profit rate of 14.5% - The ITAT partially upheld the additions but granted relief to the assessee by adjusting the net profit rate to 11% and reducing the additions for provisions based on evidence provided during appellate proceedings. Overall, the tribunal's decision aimed to balance the interests of both parties while ensuring compliance with tax regulations.
Estimation of profit - AO applying a profit rate of 20% on the contract receipt against the rate of profit declared by the appellant at 8.13% - CIT(A) directing the AO to apply a profit rate of 14.5% - The ITAT partially upheld the additions but granted relief to the assessee by adjusting the net profit rate to 11% and reducing the additions for provisions based on evidence provided during appellate proceedings. Overall, the tribunal's decision aimed to balance the interests of both parties while ensuring compliance with tax regulations.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
