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...
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.
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