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...
A seized photocopy of an agreement to sell was treated as reliable incriminating material where it was signed on every page, witnessed, and matched the subsequent registered sale deeds on consideration details, cheque particulars and witness identity; the Tribunal held that no further independent corroboration was required and sustained the addition for under-reported sale consideration. For penalty, it held that cash paid at the time of execution of a registered sale deed is distinct from the advance or specified sum targeted by the amended section 269SS, which was intended to curb cash advances in real-estate transactions; on that basis, penalty under section 271D was deleted.
A seized photocopy of an agreement to sell was treated as reliable incriminating material where it was signed on every page, witnessed, and matched the subsequent registered sale deeds on consideration details, cheque particulars and witness identity; the Tribunal held that no further independent corroboration was required and sustained the addition for under-reported sale consideration. For penalty, it held that cash paid at the time of execution of a registered sale deed is distinct from the advance or specified sum targeted by the amended section 269SS, which was intended to curb cash advances in real-estate transactions; on that basis, penalty under section 271D was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
