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...
Determination of sale consideration - reliance on photocopy of the alleged agreement to sell - The High Court scrutinized the circumstances surrounding the photocopy of the agreement to sell. It noted that the original document was not produced, and there was no other evidence to corroborate the details mentioned in the photocopy. Therefore, the court concluded that the photocopy alone could not serve as a valid basis for making additions to the assessee's income. - The court emphasized that the burden of proving the authenticity of the photocopy rested with the Revenue, especially since the entire case relied solely on it.
Determination of sale consideration - reliance on photocopy of the alleged agreement to sell - The High Court scrutinized the circumstances surrounding the photocopy of the agreement to sell. It noted that the original document was not produced, and there was no other evidence to corroborate the details mentioned in the photocopy. Therefore, the court concluded that the photocopy alone could not serve as a valid basis for making additions to the assessee's income. - The court emphasized that the burden of proving the authenticity of the photocopy rested with the Revenue, especially since the entire case relied solely on it.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
