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...
Non-resident assessee, a regular income tax filer, was subject to best judgment assessment u/s 144 for unexplained investment in mutual funds u/s 69. Assessee submitted additional evidence u/r 46A, which the Assessing Officer and CIT(A) failed to consider properly. ITAT observed assessee is an NRI with income sourced outside India, and the investment was traceable from bank statements. CIT(A) rightly deleted the addition on mutual fund investment and long-term capital gains on sale of equity-oriented mutual funds, being exempt u/s 10(38). ITAT upheld CIT(A)'s order, finding no reason to interfere given the evidence on record.
Non-resident assessee, a regular income tax filer, was subject to best judgment assessment u/s 144 for unexplained investment in mutual funds u/s 69. Assessee submitted additional evidence u/r 46A, which the Assessing Officer and CIT(A) failed to consider properly. ITAT observed assessee is an NRI with income sourced outside India, and the investment was traceable from bank statements. CIT(A) rightly deleted the addition on mutual fund investment and long-term capital gains on sale of equity-oriented mutual funds, being exempt u/s 10(38). ITAT upheld CIT(A)'s order, finding no reason to interfere given the evidence on record.
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