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: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
Presumptive taxation: where an assessee opts to declare income under the presumptive scheme and offers income accordingly, separate additions for unexplained cash bank deposits cannot be sustained; the tribunal relied on precedent holding that opting into the presumptive regime removes the obligation to explain each cash entry, and directed deletion of the addition. The appellate authority allowed the assessee's appeal and set aside the lower appellate order that had limited relief to bank debits, restoring complete relief against the addition by the assessing officer.
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