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...
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ITAT directs Assessing Officer (AO) to verify facts regarding loan/deposit investments after providing reasonable opportunity to assessee. Tribunal found no merit in additions under Section 68 for advances to Rainbow Tech, Arun Muchhala Engineering College, Arun Muchhala Research & Education Centre, and loans from Sai Shiva Developers, Mucchala Magic Land P. Ltd., and Arun Muchhala Co-owners. The tribunal noted that most disputed amounts were opening balances or partially repaid, and transactions were conducted through banking channels. Consequently, the tribunal deleted additions made under Section 68 and upheld the assessee's claim, remanding the matter back to AO for further verification with proper procedural fairness.
ITAT directs Assessing Officer (AO) to verify facts regarding loan/deposit investments after providing reasonable opportunity to assessee. Tribunal found no merit in additions under Section 68 for advances to Rainbow Tech, Arun Muchhala Engineering College, Arun Muchhala Research & Education Centre, and loans from Sai Shiva Developers, Mucchala Magic Land P. Ltd., and Arun Muchhala Co-owners. The tribunal noted that most disputed amounts were opening balances or partially repaid, and transactions were conducted through banking channels. Consequently, the tribunal deleted additions made under Section 68 and upheld the assessee's claim, remanding the matter back to AO for further verification with proper procedural fairness.
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