Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
Bogus Purchases - Credibility of Statements - The tribunal was not convinced by the appellant's argument that the initial statements were made under duress or misinterpreted. They emphasized that the retraction came after substantial delay and seemed more like an afterthought designed to escape tax liability. - Despite the retraction, the tribunal held that the original statements admitting to bogus purchases and additional income were credible. They relied on the timing of the retraction and the specifics of the declarations made during the survey. The admissions of additional income were deemed to substantiate the reopening of assessments for the years in question. The tribunal supported the additions made to the taxable income based on these declarations.
Bogus Purchases - Credibility of Statements - The tribunal was not convinced by the appellant's argument that the initial statements were made under duress or misinterpreted. They emphasized that the retraction came after substantial delay and seemed more like an afterthought designed to escape tax liability. - Despite the retraction, the tribunal held that the original statements admitting to bogus purchases and additional income were credible. They relied on the timing of the retraction and the specifics of the declarations made during the survey. The admissions of additional income were deemed to substantiate the reopening of assessments for the years in question. The tribunal supported the additions made to the taxable income based on these declarations.
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