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...
Project Falcon material, standing alone, could not justify an addition under section 68 where the assessee had already recorded the option-trading profit in its profit and loss account, the trade data showed both gains and losses, and there was no direct assessee-specific evidence of a manipulative reversal-trade arrangement. The Tribunal held that the proposed addition would also amount to double taxation, so the deletion of the section 68 addition and the related commission disallowance under section 69C was upheld. On the alleged accommodation loan, the assessee discharged the burden by producing cheque payment, books, confirmations, bank statements and repayment evidence, while the lender's financials showed creditworthiness; in the absence of contrary inquiry or direct linkage, the section 68 addition was unsustainable and its deletion was affirmed.
Project Falcon material, standing alone, could not justify an addition under section 68 where the assessee had already recorded the option-trading profit in its profit and loss account, the trade data showed both gains and losses, and there was no direct assessee-specific evidence of a manipulative reversal-trade arrangement. The Tribunal held that the proposed addition would also amount to double taxation, so the deletion of the section 68 addition and the related commission disallowance under section 69C was upheld. On the alleged accommodation loan, the assessee discharged the burden by producing cheque payment, books, confirmations, bank statements and repayment evidence, while the lender's financials showed creditworthiness; in the absence of contrary inquiry or direct linkage, the section 68 addition was unsustainable and its deletion was affirmed.
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