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 held that a reassessment addition based on a third-party unsigned excel sheet could not be sustained without correlation to the assessee's transaction and without corroborative evidence. The sheet related to a different project and an earlier period, while the assessee's property purchase was in another project and was shown as paid by cheque. As the Assessing Officer failed to establish any actual cash payment or produce supporting statements, and the developer's affidavit denied receipt of cash, the material was insufficient to prove unexplained investment. The addition was deleted and the assessee's appeal was allowed.
ITAT held that a reassessment addition based on a third-party unsigned excel sheet could not be sustained without correlation to the assessee's transaction and without corroborative evidence. The sheet related to a different project and an earlier period, while the assessee's property purchase was in another project and was shown as paid by cheque. As the Assessing Officer failed to establish any actual cash payment or produce supporting statements, and the developer's affidavit denied receipt of cash, the material was insufficient to prove unexplained investment. The addition was deleted and the assessee's appeal was allowed.
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