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 High Court dealt with a case involving unexplained cash credit u/s 68 of the Income Tax Act. The assessee had surrendered unaccounted income during a survey, which was offered for tax. The ITAT deleted the addition, allowing telescopic benefit by linking surrendered income to cash deposits in the bank account as maturity proceeds of hundies. ITAT's decision was based on thorough analysis of facts, documents, and evidence. The High Court upheld ITAT's findings, stating no legal error was found. The benefit of telescoping was justified as per precedent. The department failed to prove the source of bank deposits was related to a scam. No substantial question of law arose, and the appeal was decided against the revenue.
The High Court dealt with a case involving unexplained cash credit u/s 68 of the Income Tax Act. The assessee had surrendered unaccounted income during a survey, which was offered for tax. The ITAT deleted the addition, allowing telescopic benefit by linking surrendered income to cash deposits in the bank account as maturity proceeds of hundies. ITAT's decision was based on thorough analysis of facts, documents, and evidence. The High Court upheld ITAT's findings, stating no legal error was found. The benefit of telescoping was justified as per precedent. The department failed to prove the source of bank deposits was related to a scam. No substantial question of law arose, and the appeal was decided against the revenue.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
