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 estimated gross on-money receipts could not be taxed in full where the record also showed unaccounted funds being routed into the books as unsecured loans through the admitted modus operandi. Because the assessee failed to prove the genuineness and creditworthiness of the lenders, the unsecured loans were treated as unexplained and the CIT(A)'s restricted additions were sustained for the relevant assessment years. The Tribunal also rejected further telescoping based on income earlier declared, and upheld the CIT(A)'s approach as the correct basis of taxation. The Revenue's appeal and the assessee's appeals were dismissed.
ITAT held that estimated gross on-money receipts could not be taxed in full where the record also showed unaccounted funds being routed into the books as unsecured loans through the admitted modus operandi. Because the assessee failed to prove the genuineness and creditworthiness of the lenders, the unsecured loans were treated as unexplained and the CIT(A)'s restricted additions were sustained for the relevant assessment years. The Tribunal also rejected further telescoping based on income earlier declared, and upheld the CIT(A)'s approach as the correct basis of taxation. The Revenue's appeal and the assessee's appeals were dismissed.
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