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 on the basis of declaration made by assessee during a search action u/s 132 - The ITAT found no merit in the revenue's arguments, noting that the addition was based solely on the assessee's statement during the search. The ITAT emphasized that under the scheme of Income-tax, only the correct income should be taxed, and the CBDT instruction dated 10.03.2003 restricts making additions based on mere confessions during search/survey without corroborative evidence. The ITAT concluded that the addition made by the revenue authorities was not justified and ordered its deletion.
Addition on the basis of declaration made by assessee during a search action u/s 132 - The ITAT found no merit in the revenue's arguments, noting that the addition was based solely on the assessee's statement during the search. The ITAT emphasized that under the scheme of Income-tax, only the correct income should be taxed, and the CBDT instruction dated 10.03.2003 restricts making additions based on mere confessions during search/survey without corroborative evidence. The ITAT concluded that the addition made by the revenue authorities was not justified and ordered its deletion.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
