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 ITAT held that the reopening of assessment u/s 147 based on cash deposits during the year was invalid. The assessee demonstrated the source of cash deposits by proving withdrawal of Rs. 20 lakhs earlier, which was used for subsequent deposits from 28.10.2010 to 15.03.2011. Consequently, the ITAT allowed the assessee's grounds and deleted the addition made u/s 69A using the peak credit method.
The ITAT held that the reopening of assessment u/s 147 based on cash deposits during the year was invalid. The assessee demonstrated the source of cash deposits by proving withdrawal of Rs. 20 lakhs earlier, which was used for subsequent deposits from 28.10.2010 to 15.03.2011. Consequently, the ITAT allowed the assessee's grounds and deleted the addition made u/s 69A using the peak credit method.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
