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...
The ITAT Delhi ruled on an assessment u/s 153A, focusing on additions u/s 68 and undisclosed sources based on the Assessee's bank statement. The Tribunal found no incriminating material during the search to support the additions. Citing precedents like Kabul Chawla and Meeta Gutgutia, the Tribunal deleted the addition. The Supreme Court in Abhisar Build well P. Ltd. held that additions without incriminating material from a search or requisition are invalid. The Assessee's appeal was allowed.
The ITAT Delhi ruled on an assessment u/s 153A, focusing on additions u/s 68 and undisclosed sources based on the Assessee's bank statement. The Tribunal found no incriminating material during the search to support the additions. Citing precedents like Kabul Chawla and Meeta Gutgutia, the Tribunal deleted the addition. The Supreme Court in Abhisar Build well P. Ltd. held that additions without incriminating material from a search or requisition are invalid. The Assessee's appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4894 
