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 considered a case involving denial of exemption u/s 10(38) for alleged bogus LTCG. The assessee invested in shares of a company deemed unreliable due to manipulation by brokers for undue benefits. The ITAT emphasized that profit magnitude does not establish the genuineness of an investee company. Despite the assessee's small profit, it was held that the transaction's genuineness cannot be determined solely by profit amount. The ITAT upheld the decision of the CIT (Appeals), dismissing the assessee's appeal based on the lack of error in the earlier order.
The ITAT considered a case involving denial of exemption u/s 10(38) for alleged bogus LTCG. The assessee invested in shares of a company deemed unreliable due to manipulation by brokers for undue benefits. The ITAT emphasized that profit magnitude does not establish the genuineness of an investee company. Despite the assessee's small profit, it was held that the transaction's genuineness cannot be determined solely by profit amount. The ITAT upheld the decision of the CIT (Appeals), dismissing the assessee's appeal based on the lack of error in the earlier order.
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