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...
Undisclosed income computation u/s 158-BB for search assessment cases. Assessing officer can consider materials found during search and other available information relatable to such evidence. Assessment based on search results and post-search enquiries. Assessee's arguments on lack of opportunity and non-consideration of employee affidavits rejected. Recovery of documents like correspondence, maps, stock positions, and truck loads from assessee's premises indicated undisclosed income from liquor business run through employees and benami companies despite licenses not in assessee's name. Cross-examination of persons whose statements were relied upon afforded to assessee. Rent agreement signed by assessee as contractor further supported findings. Tribunal upheld reassessment of undisclosed income earned through ghost/benami companies. Decided against assessee.
Undisclosed income computation u/s 158-BB for search assessment cases. Assessing officer can consider materials found during search and other available information relatable to such evidence. Assessment based on search results and post-search enquiries. Assessee's arguments on lack of opportunity and non-consideration of employee affidavits rejected. Recovery of documents like correspondence, maps, stock positions, and truck loads from assessee's premises indicated undisclosed income from liquor business run through employees and benami companies despite licenses not in assessee's name. Cross-examination of persons whose statements were relied upon afforded to assessee. Rent agreement signed by assessee as contractor further supported findings. Tribunal upheld reassessment of undisclosed income earned through ghost/benami companies. Decided against assessee.
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