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...
ITAT affirmed re-assessment notice for AY 2013-14 as valid under TOLA, finding no procedural objections by the assessee. On unexplained bank deposits, the tribunal determined a taxable profit margin of 8% rather than the assessee's proposed 3-7% range, lacking substantive evidence. The tribunal directed the Assessing Officer to separately compute business income and interest income, with TDS on interest to be brought to tax under income from other sources. The appeal was partly allowed, with the re-assessment proceedings upheld and a modified approach to taxing unexplained deposits implemented.
ITAT affirmed re-assessment notice for AY 2013-14 as valid under TOLA, finding no procedural objections by the assessee. On unexplained bank deposits, the tribunal determined a taxable profit margin of 8% rather than the assessee's proposed 3-7% range, lacking substantive evidence. The tribunal directed the Assessing Officer to separately compute business income and interest income, with TDS on interest to be brought to tax under income from other sources. The appeal was partly allowed, with the re-assessment proceedings upheld and a modified approach to taxing unexplained deposits implemented.
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