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 set aside the disallowance of freight charges, holding that mere suspicion without proof cannot justify rejecting expenses substantiated by audited accounts and vouchers. The disallowance under section 14A was deleted due to the AO's failure to record proper satisfaction before making additions. Additions based solely on Form 26AS mismatch were reversed as the assessee declared the amount in a subsequent year, preventing double taxation. The issue of carry forward losses was remitted to the AO for verification in accordance with law, with a direction to afford the assessee an opportunity of hearing. Disallowance of interest expenditure was also reversed, as the assessee had interest-free funds evidenced by loans and inventory financing, precluding blanket disallowance of finance costs. The appeal was allowed in part, with remand and deletion of certain additions.
The ITAT set aside the disallowance of freight charges, holding that mere suspicion without proof cannot justify rejecting expenses substantiated by audited accounts and vouchers. The disallowance under section 14A was deleted due to the AO's failure to record proper satisfaction before making additions. Additions based solely on Form 26AS mismatch were reversed as the assessee declared the amount in a subsequent year, preventing double taxation. The issue of carry forward losses was remitted to the AO for verification in accordance with law, with a direction to afford the assessee an opportunity of hearing. Disallowance of interest expenditure was also reversed, as the assessee had interest-free funds evidenced by loans and inventory financing, precluding blanket disallowance of finance costs. The appeal was allowed in part, with remand and deletion of certain additions.
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