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 upheld the deletion of additions related to unexplained sundry creditors, finding no infirmity in the CIT(A)'s acceptance of additional evidence, including an agency agreement justifying adjustments between parties. The AO's jurisdiction to scrutinize sundry creditors was affirmed but the related disallowance under section 14A was already deleted by CIT(A) and not challenged, rendering that issue final. The assessee's challenge to interest disallowance under limited scrutiny was dismissed. However, regarding disallowance under section 36(1)(iii), the ITAT reversed CIT(A)'s directive for recomputation, holding that the assessee's demonstration of sufficient interest-free funds to cover advances negated any disallowance. Consequently, the assessee's ground on this point was allowed, resulting in the overall dismissal of the revenue's appeal and partial allowance of the assessee's cross-objection.
The ITAT upheld the deletion of additions related to unexplained sundry creditors, finding no infirmity in the CIT(A)'s acceptance of additional evidence, including an agency agreement justifying adjustments between parties. The AO's jurisdiction to scrutinize sundry creditors was affirmed but the related disallowance under section 14A was already deleted by CIT(A) and not challenged, rendering that issue final. The assessee's challenge to interest disallowance under limited scrutiny was dismissed. However, regarding disallowance under section 36(1)(iii), the ITAT reversed CIT(A)'s directive for recomputation, holding that the assessee's demonstration of sufficient interest-free funds to cover advances negated any disallowance. Consequently, the assessee's ground on this point was allowed, resulting in the overall dismissal of the revenue's appeal and partial allowance of the assessee's cross-objection.
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