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...
Addition u/s 68 for director's loan ledger account was made by assessing officer (AO) considering transactions not matching previous year's financial statements. Assessee stated transactions pertained to prior assessment years. Tribunal held previous year's transactions cannot be considered income in current assessment year. Transactions related to FY 2012-13 and 2013-14, for which AO passed order u/s 143(3) on 29.01.2016 accepting closing balance of director's ledger account. AO cannot consider opening balance in current assessment year for making addition, relying on Sridev Enterprises judgment. Tribunal upheld CIT(Appeals) order deleting the addition, decided in favor of assessee.
Addition u/s 68 for director's loan ledger account was made by assessing officer (AO) considering transactions not matching previous year's financial statements. Assessee stated transactions pertained to prior assessment years. Tribunal held previous year's transactions cannot be considered income in current assessment year. Transactions related to FY 2012-13 and 2013-14, for which AO passed order u/s 143(3) on 29.01.2016 accepting closing balance of director's ledger account. AO cannot consider opening balance in current assessment year for making addition, relying on Sridev Enterprises judgment. Tribunal upheld CIT(Appeals) order deleting the addition, decided in favor of assessee.
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