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...
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
Presumptive taxation under section 44AD was applied to estimate net profit where the assessee failed to file returns or participate in assessment proceedings; the AO had applied an 18% net profit rate based on TDS under section 194C, but the Tribunal considered the lack of participation and limited evidence and reduced the presumptive net profit rate to 8%, computing the assessee's income accordingly and deleting the remaining additions. Grounds of appeal were partly allowed.
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