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 being 10 percent out of various expenses - books of assessee are duly audited under section 44AB of the Act - The Appellate Tribunal upheld the arguments presented by the assessee. They noted that the books of account were audited under section 44AB of the Income Tax Act and were not rejected by the AO. Therefore, the adhoc disallowance based on presumptions was deemed unsustainable, citing the precedent set by the Supreme Court. - The Tribunal emphasized that the AO's failure to reject the books of account further weakened the basis for the adhoc disallowance.
Addition being 10 percent out of various expenses - books of assessee are duly audited under section 44AB of the Act - The Appellate Tribunal upheld the arguments presented by the assessee. They noted that the books of account were audited under section 44AB of the Income Tax Act and were not rejected by the AO. Therefore, the adhoc disallowance based on presumptions was deemed unsustainable, citing the precedent set by the Supreme Court. - The Tribunal emphasized that the AO's failure to reject the books of account further weakened the basis for the adhoc disallowance.
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