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...
The Income Tax Appellate Tribunal held that when the assessing officer considered undisclosed income based on seized material, they ought to have also considered undisclosed losses from the same material and allowed set-off. Failing to do so constituted a mistake apparent from record u/s 254(2). The Tribunal directed the assessing officer to allow set-off of undisclosed losses of the immediately preceding year against the undisclosed income for the impugned year, following principles of equity, justice and interpreting seized material as a whole.
The Income Tax Appellate Tribunal held that when the assessing officer considered undisclosed income based on seized material, they ought to have also considered undisclosed losses from the same material and allowed set-off. Failing to do so constituted a mistake apparent from record u/s 254(2). The Tribunal directed the assessing officer to allow set-off of undisclosed losses of the immediately preceding year against the undisclosed income for the impugned year, following principles of equity, justice and interpreting seized material as a whole.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
