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 addressed the validity of additions in an assessment u/s 153A without incriminating material post a search u/s 132. Citing Abhisar Buildwell (P) Ltd., the Tribunal held that if no incriminating material is found during a search, the AO cannot assess or reassess completed/unabated assessments. Consequently, additions made without such material cannot stand. The Tribunal deleted the additions by the AO, including commission income, as they lacked a basis in incriminating material. Ground no. 1 was allowed in favor of the assessee.
The ITAT Delhi addressed the validity of additions in an assessment u/s 153A without incriminating material post a search u/s 132. Citing Abhisar Buildwell (P) Ltd., the Tribunal held that if no incriminating material is found during a search, the AO cannot assess or reassess completed/unabated assessments. Consequently, additions made without such material cannot stand. The Tribunal deleted the additions by the AO, including commission income, as they lacked a basis in incriminating material. Ground no. 1 was allowed in favor of the assessee.
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