Admissibility of electronic evidence bars undervaluation demands where printouts, retracted statements and no cross-examination leave the case unprove...
Limitation in oppression and mismanagement proceedings: prior knowledge of removal and dilution barred the challenge, with valuation directions upheld...
Reimbursement of salary cost for seconded employees was not taxable as fees for technical services where the secondees worked under the control of the Indian entity and the payment contained no separate service element. Applying the earlier ruling in the group concern case, the ITAT found no material factual distinction for the year under consideration and treated the receipt as falling within the employer-employee salary exclusion. The addition made on that basis was deleted. The challenge to the validity of the assessment order was not pressed and was therefore not admitted.
Reimbursement of salary cost for seconded employees was not taxable as fees for technical services where the secondees worked under the control of the Indian entity and the payment contained no separate service element. Applying the earlier ruling in the group concern case, the ITAT found no material factual distinction for the year under consideration and treated the receipt as falling within the employer-employee salary exclusion. The addition made on that basis was deleted. The challenge to the validity of the assessment order was not pressed and was therefore not admitted.
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