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...
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ITAT partially allowed the appeal, reducing the estimated income addition from 10% to 1.52% of declared turnover. Despite concerns about unaudited accounts and non-filing of returns, the tribunal recognized the assessee's self-declared figures and permitted a set-off of Rs. 1,49,165/-. The decision mandates the assessee to reconcile financial discrepancies while moderating the income addition imposed by the Assessing Officer, thereby striking a balance between procedural compliance and equitable tax assessment.
ITAT partially allowed the appeal, reducing the estimated income addition from 10% to 1.52% of declared turnover. Despite concerns about unaudited accounts and non-filing of returns, the tribunal recognized the assessee's self-declared figures and permitted a set-off of Rs. 1,49,165/-. The decision mandates the assessee to reconcile financial discrepancies while moderating the income addition imposed by the Assessing Officer, thereby striking a balance between procedural compliance and equitable tax assessment.
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