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 the addition of capital gain due to undeclared transaction. The property's ownership was crucial, as the property was not owned by the HUF as claimed. The claim of transfer under HUF partition was rejected as unproven. The "family settlement" theory was introduced late and not supported by evidence. The sale-deed executed was deemed taxable, as it involved a genuine transaction between the assessee and his brothers. The unexplained cash deposits were justified by the Cash-Book, leading to deletion of the addition. Overall, the capital gain addition was upheld, while the unexplained cash deposits addition was deleted.
The ITAT considered the addition of capital gain due to undeclared transaction. The property's ownership was crucial, as the property was not owned by the HUF as claimed. The claim of transfer under HUF partition was rejected as unproven. The "family settlement" theory was introduced late and not supported by evidence. The sale-deed executed was deemed taxable, as it involved a genuine transaction between the assessee and his brothers. The unexplained cash deposits were justified by the Cash-Book, leading to deletion of the addition. Overall, the capital gain addition was upheld, while the unexplained cash deposits addition was deleted.
Note: It is a system-generated summary and is for quick reference only.
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