Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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The ITAT Delhi considered an addition u/s 69A r.w.s. 115BBE for cash deposited during demonetization as unexplained. The assessee's explanation of cash deposits from sales was rejected by AO and CIT(A) despite not rejecting books of accounts. The Tribunal held that absence of cash sales in prior years doesn't justify rejecting the explanation when books were not rejected and trading results were accepted. Referring to precedents, the Tribunal directed deletion of additions u/s 69A/68, emphasizing that cash deposits were from declared sales proceeds. Citing cases like Anantpur Kalpana and Mukesh K. Waghasia, the Tribunal ruled in favor of the assessee, highlighting the importance of supporting evidence in such matters.
The ITAT Delhi considered an addition u/s 69A r.w.s. 115BBE for cash deposited during demonetization as unexplained. The assessee's explanation of cash deposits from sales was rejected by AO and CIT(A) despite not rejecting books of accounts. The Tribunal held that absence of cash sales in prior years doesn't justify rejecting the explanation when books were not rejected and trading results were accepted. Referring to precedents, the Tribunal directed deletion of additions u/s 69A/68, emphasizing that cash deposits were from declared sales proceeds. Citing cases like Anantpur Kalpana and Mukesh K. Waghasia, the Tribunal ruled in favor of the assessee, highlighting the importance of supporting evidence in such matters.
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