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...
Disallowance based on third party information about unexplained purchases was challenged. ITAT held that the additions were unsustainable as the disallowance was solely based on unverified third-party information gathered by the Department's Investigation Wing, without providing an opportunity for cross-examination to the assessee, who had prima facie substantiated the purchases through documentation like bills, confirmed accounts, and VAT registration of sellers. The purchases were found acceptable, and the consequent addition to income was directed to be deleted, favoring the assessee.
Disallowance based on third party information about unexplained purchases was challenged. ITAT held that the additions were unsustainable as the disallowance was solely based on unverified third-party information gathered by the Department's Investigation Wing, without providing an opportunity for cross-examination to the assessee, who had prima facie substantiated the purchases through documentation like bills, confirmed accounts, and VAT registration of sellers. The purchases were found acceptable, and the consequent addition to income was directed to be deleted, favoring the assessee.
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