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 High Court upheld the validity of reassessment u/s 153C and rejected the contention of reopening assessment u/s 147. The Assessing Officer relied on the material seized during the search for making additions in the assessees' hands. The Court affirmed the estimation of income on bogus purchases by the Tribunal at 6%, as it concurred with the reasoned decision of the fact-finding authorities. Consistent with similar cases involving accommodation entries, the 6% addition on estimated purchases maintained.
The High Court upheld the validity of reassessment u/s 153C and rejected the contention of reopening assessment u/s 147. The Assessing Officer relied on the material seized during the search for making additions in the assessees' hands. The Court affirmed the estimation of income on bogus purchases by the Tribunal at 6%, as it concurred with the reasoned decision of the fact-finding authorities. Consistent with similar cases involving accommodation entries, the 6% addition on estimated purchases maintained.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
