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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...
Assessment completed u/s 153A - addition on account of peak balance maintained by the assessee with HSBC Bank, Geneva - The Appellate Tribunal, after reviewing the submissions and record, found in favor of the appellant. They emphasized the absence of incriminating material and reliable evidence establishing ownership of the foreign bank account. Consequently, the Tribunal quashed the assessment orders of the lower authorities, effectively allowing the appellant's appeal.
Assessment completed u/s 153A - addition on account of peak balance maintained by the assessee with HSBC Bank, Geneva - The Appellate Tribunal, after reviewing the submissions and record, found in favor of the appellant. They emphasized the absence of incriminating material and reliable evidence establishing ownership of the foreign bank account. Consequently, the Tribunal quashed the assessment orders of the lower authorities, effectively allowing the appellant's appeal.
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