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 Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
The Appellate Tribunal addressed several issues. Regarding quantification of profit element on unsubstantiated purchases, the matter was sent back to the Assessing Officer (\u/s) for limited addition based on profit rate variance. Disallowance of interest on loan was allowed for further evidence consideration. Addition \u/s 68 for unsecured loans was revisited due to new documents submitted, leading to a direction for reassessment by the AO. The assessee's appeals were allowed for statistical purposes. The AO was instructed to provide a fair opportunity for the assessee in each case.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
