Marketing support and subcontracted client contracts: no agency permanent establishment under Article 5 DTAA; arm's-length pricing bars profit attribu...
Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Addition under s. 69 for cash deposits during the demonetisation period was disputed on the ground that the deposits were already covered by additional income disclosed and taxed pursuant to settlement. The settlement order under s. 245D(4) recorded telescoping of cash balances of the assessee and a related trust against the additional income offered for earlier years, and the AO failed to show that such undisclosed income had been deployed elsewhere or that any outside-the-books investments existed. Applying the rule against double taxation of the same income and extending telescoping, the cash deposits were held explained out of previously taxed income, and no separate addition was sustainable; the Revenue's appeal was dismissed - ITAT
Addition under s. 69 for cash deposits during the demonetisation period was disputed on the ground that the deposits were already covered by additional income disclosed and taxed pursuant to settlement. The settlement order under s. 245D(4) recorded telescoping of cash balances of the assessee and a related trust against the additional income offered for earlier years, and the AO failed to show that such undisclosed income had been deployed elsewhere or that any outside-the-books investments existed. Applying the rule against double taxation of the same income and extending telescoping, the cash deposits were held explained out of previously taxed income, and no separate addition was sustainable; the Revenue's appeal was dismissed - ITAT
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