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 50C r.w.s. 56(2)(vii) (b) - the buyer of the property - The Tribunal (ITAT) ruled that since the assesses were buyers, Section 50C did not apply, and Section 56(2)(vii)(b) did not apply as the property was not acquired without consideration. The retrospective application of Section 56(2)(vii)(b) was also rejected. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained. Consequently, the appeals by both assesses were allowed. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained.
Addition u/s 50C r.w.s. 56(2)(vii) (b) - the buyer of the property - The Tribunal (ITAT) ruled that since the assesses were buyers, Section 50C did not apply, and Section 56(2)(vii)(b) did not apply as the property was not acquired without consideration. The retrospective application of Section 56(2)(vii)(b) was also rejected. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained. Consequently, the appeals by both assesses were allowed. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained.
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