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 68 in the hands of partnership firm - capital introduced by five partners, which in turn was out of the loan advanced - The Appellate Tribunal (AT) examined the arguments and evidence presented by both parties. It held that the responsibility of the firm ends once it provides satisfactory evidence regarding the introduction of capital by its partners. The Tribunal cited precedents where it was established that once the partner invests capital, the burden shifts to that individual to explain the source of the investment. Therefore, the Tribunal directed the deletion of the addition made by the AO.
Addition u/s 68 in the hands of partnership firm - capital introduced by five partners, which in turn was out of the loan advanced - The Appellate Tribunal (AT) examined the arguments and evidence presented by both parties. It held that the responsibility of the firm ends once it provides satisfactory evidence regarding the introduction of capital by its partners. The Tribunal cited precedents where it was established that once the partner invests capital, the burden shifts to that individual to explain the source of the investment. Therefore, the Tribunal directed the deletion of the addition made by the AO.
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