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...
Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
Bogus purchase additions based on estimated profit were deleted where the assessee produced GST-linked purchase records, quantitative stock statements, movement details and payment evidence, and none of those books or results were found defective. In the absence of rejection of books or any finding that the disclosed gross profit was unreasonable, an 8% profit estimate on alleged bogus purchases was impermissible. The addition for alleged cessation of liability was also deleted because the ledger balance was supported by invoices and bank payments, and no adverse factual finding displaced that documentary evidence.
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