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 HC held that no unexplained money under s.69A arose in respect of the cash-in-hand carried from FY 2015-16 to FY 2016-17 and deposited during demonetisation. The court found an inextricable nexus between disclosed bank withdrawals, advances to third parties, interest receipts and subsequent return of funds evidenced in the assessee's balance sheet and the return of income filed and processed under s.143(1). Absence of a mandatory s.143(2) scrutiny notice rendered the return final for that assessment year, and the AO failed to demonstrate that the cash constituted unexplained income warranting invocation of s.69A. Decision: in favour of the assessee.
The HC held that no unexplained money under s.69A arose in respect of the cash-in-hand carried from FY 2015-16 to FY 2016-17 and deposited during demonetisation. The court found an inextricable nexus between disclosed bank withdrawals, advances to third parties, interest receipts and subsequent return of funds evidenced in the assessee's balance sheet and the return of income filed and processed under s.143(1). Absence of a mandatory s.143(2) scrutiny notice rendered the return final for that assessment year, and the AO failed to demonstrate that the cash constituted unexplained income warranting invocation of s.69A. Decision: in favour of the assessee.
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