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 ITAT held that once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
The ITAT held that once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
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