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 40A(3) - Cash expenditure - assessee has made payments to the land owners exceeding INR 20,000/- - The Tribunal agreed with the appellant's argument to some extent, acknowledging that the disallowance should have been restricted to 20% of the total expenditure exceeding the prescribed limit. While the appellant failed to provide substantial evidence of business expediency, the Tribunal recognized that the disallowance should adhere to the provisions of section 40A(3), limiting it to 20%.
Addition u/s 40A(3) - Cash expenditure - assessee has made payments to the land owners exceeding INR 20,000/- - The Tribunal agreed with the appellant's argument to some extent, acknowledging that the disallowance should have been restricted to 20% of the total expenditure exceeding the prescribed limit. While the appellant failed to provide substantial evidence of business expediency, the Tribunal recognized that the disallowance should adhere to the provisions of section 40A(3), limiting it to 20%.
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