Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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ITAT upheld the assessee's appeal and directed deletion of the addition treating receipts as income from FTS/FIS. The Tribunal found the payments arose under the same agreement dated 20.02.2017, covering software licence and ancillary support/AMC, and that the factual matrix identical to AY 2019-20 compelled the same conclusion as in the earlier ITAT decision relied upon by the assessee. The Revenue failed to adduce contrary material or distinguish the precedent. Consequently, the addition made by the AO is set aside and the grounds of appeal filed by the assessee are allowed.
ITAT upheld the assessee's appeal and directed deletion of the addition treating receipts as income from FTS/FIS. The Tribunal found the payments arose under the same agreement dated 20.02.2017, covering software licence and ancillary support/AMC, and that the factual matrix identical to AY 2019-20 compelled the same conclusion as in the earlier ITAT decision relied upon by the assessee. The Revenue failed to adduce contrary material or distinguish the precedent. Consequently, the addition made by the AO is set aside and the grounds of appeal filed by the assessee are allowed.
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