Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Cash payments exceeding Rs. 20,000 were made, and the assessee provided a statement on oath, affidavits from the vendor, and explanations about the vendor's father's ill health and jail term, as well as the precondition of cash payment for the land deal. The appellate authority erred in rejecting these submissions and not considering business expediency. Regarding development expenses, the assessing officer disallowed 10% due to lack of vouchers, which was reduced to 5% by the appellate authority. Since no further evidence was produced, the Appellate Tribunal declined to interfere with the appellate authority's order on this issue.
Cash payments exceeding Rs. 20,000 were made, and the assessee provided a statement on oath, affidavits from the vendor, and explanations about the vendor's father's ill health and jail term, as well as the precondition of cash payment for the land deal. The appellate authority erred in rejecting these submissions and not considering business expediency. Regarding development expenses, the assessing officer disallowed 10% due to lack of vouchers, which was reduced to 5% by the appellate authority. Since no further evidence was produced, the Appellate Tribunal declined to interfere with the appellate authority's order on this issue.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4875 
