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...
Dominant issue: whether the assessing officer's estimate of gross agricultural receipts should be sustained. Reasoning: AO conceded the taxpayer carried on agricultural activity but disputed the correctness of reported gross agricultural receipts; taxpayer produced invoices and buyer confirmations but also some self-serving documents of limited evidentiary value; taxpayer's historical consistency in reporting agricultural income was considered. Outcome: directed AO to make an ad-hoc addition equal to 10% of agricultural receipts, taxed at normal rates; appeal partly allowed. - ITAT
Dominant issue: whether the assessing officer's estimate of gross agricultural receipts should be sustained. Reasoning: AO conceded the taxpayer carried on agricultural activity but disputed the correctness of reported gross agricultural receipts; taxpayer produced invoices and buyer confirmations but also some self-serving documents of limited evidentiary value; taxpayer's historical consistency in reporting agricultural income was considered. Outcome: directed AO to make an ad-hoc addition equal to 10% of agricultural receipts, taxed at normal rates; appeal partly allowed. - ITAT
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