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...
ITAT addressed taxation of income declared on excess stock found during survey, applying the principle that surrendered income arising from the same business activities must be taxed as business income rather than treated as undisclosed investment; outcome: CIT(A)'s direction to treat the surrender as regular business income is upheld. On disallowance of expenses for lack of documentary support, AO's additions were restored because vouchers were treated as self-made and expenses paid in cash. Claims for twice-booked meal expenses were disallowed and CIT(A)'s partial relief set aside. Vehicle expenditure disallowance based on absence of logbook/support was also restored to the AO's higher disallowance.
ITAT addressed taxation of income declared on excess stock found during survey, applying the principle that surrendered income arising from the same business activities must be taxed as business income rather than treated as undisclosed investment; outcome: CIT(A)'s direction to treat the surrender as regular business income is upheld. On disallowance of expenses for lack of documentary support, AO's additions were restored because vouchers were treated as self-made and expenses paid in cash. Claims for twice-booked meal expenses were disallowed and CIT(A)'s partial relief set aside. Vehicle expenditure disallowance based on absence of logbook/support was also restored to the AO's higher disallowance.
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