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...
Remittances to Indian NRE accounts were held explained where the assessee produced tax residency certificates, foreign tax returns, bank statements and Indian account records showing long-standing foreign income and accumulated savings. The Tribunal found that the funds were transferred through banking channels with a direct nexus to the foreign bank account, so the explanation could not be rejected merely for non-compliance at assessment stage or for comparing remittances with the wrong income period. Because the remittances were satisfactorily explained, the linked investment in immovable property was also not treated as unexplained. The additions under section 69 were deleted.
Remittances to Indian NRE accounts were held explained where the assessee produced tax residency certificates, foreign tax returns, bank statements and Indian account records showing long-standing foreign income and accumulated savings. The Tribunal found that the funds were transferred through banking channels with a direct nexus to the foreign bank account, so the explanation could not be rejected merely for non-compliance at assessment stage or for comparing remittances with the wrong income period. Because the remittances were satisfactorily explained, the linked investment in immovable property was also not treated as unexplained. The additions under section 69 were deleted.
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