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 CIT(A) partly allowed and restricted the addition on account of commission expenses at 0.25% as compared to 2% adopted by the Assessing Officer. The coordinate bench of the Tribunal, in a similar case involving the assessee's sister concern, deleted the addition on account of non-genuine profit/loss in illiquid options and consequently also deleted the notional addition of commission u/s 69C. Following the same, the addition on account of commission expenses u/s 69C is deleted. Regarding the addition on account of non-genuine purchases, the coordinate bench of the Tribunal, in a similar case involving the assessee's sister concern, deleted the addition on account of non-genuine purchases. In the absence of contradictory material on facts and law, the addition on account of non-genuine purchases is also deleted, respectfully following the Tribunal's decision in the cited case.
The CIT(A) partly allowed and restricted the addition on account of commission expenses at 0.25% as compared to 2% adopted by the Assessing Officer. The coordinate bench of the Tribunal, in a similar case involving the assessee's sister concern, deleted the addition on account of non-genuine profit/loss in illiquid options and consequently also deleted the notional addition of commission u/s 69C. Following the same, the addition on account of commission expenses u/s 69C is deleted. Regarding the addition on account of non-genuine purchases, the coordinate bench of the Tribunal, in a similar case involving the assessee's sister concern, deleted the addition on account of non-genuine purchases. In the absence of contradictory material on facts and law, the addition on account of non-genuine purchases is also deleted, respectfully following the Tribunal's decision in the cited case.
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