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...
Disallowance of raw material consumption - rejection of the books of account - The Appellate Tribunal finds that the AO's ad hoc disallowance without specific reasons for rejecting the books of accounts is unjustified. Mere deviation in the percentage of raw material consumption does not warrant such action. The Tribunal refers to precedent to support its decision, emphasizing that when books of accounts are regularly maintained and audited without adverse opinion, they should be considered correct unless proven otherwise by the revenue.
Disallowance of raw material consumption - rejection of the books of account - The Appellate Tribunal finds that the AO's ad hoc disallowance without specific reasons for rejecting the books of accounts is unjustified. Mere deviation in the percentage of raw material consumption does not warrant such action. The Tribunal refers to precedent to support its decision, emphasizing that when books of accounts are regularly maintained and audited without adverse opinion, they should be considered correct unless proven otherwise by the revenue.
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