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...
AO failed to conduct proper inquiry regarding alleged bogus long term capital gain by not examining bankers, brokers, Demat agencies involved in transactions, ascertaining source of funds, verifying synchronized trades, summoning person who deposited cheques in assessee's account. Connivance of bankers, brokers, Demat agencies suspected in such scams. AO directed to make larger inquiry, summon relevant parties, determine real income and rightful assessee. Matter remanded to AO for fresh adjudication after due inquiry, providing fair opportunity to assessee. Appeal allowed.
AO failed to conduct proper inquiry regarding alleged bogus long term capital gain by not examining bankers, brokers, Demat agencies involved in transactions, ascertaining source of funds, verifying synchronized trades, summoning person who deposited cheques in assessee's account. Connivance of bankers, brokers, Demat agencies suspected in such scams. AO directed to make larger inquiry, summon relevant parties, determine real income and rightful assessee. Matter remanded to AO for fresh adjudication after due inquiry, providing fair opportunity to assessee. Appeal allowed.
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