Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
BSE futures and options trade profits disclosed for tax were supported by contract notes, tax records, bank statements, annual reports, transaction statements and account confirmations. Treating those profits as unexplained cash credit requires material showing that the broker or counterparty was tainted; no such material was identified. The preponderance-of-probabilities assessment distinguished alleged pre-arranged reversal trades involving loss-making entities from profitable trades with no identified loss-making counterparty. The trades were accepted as genuine, resulting in deletion of the unexplained cash credit addition and the consequential alleged commission expenditure addition under Section 69C.
BSE futures and options trade profits disclosed for tax were supported by contract notes, tax records, bank statements, annual reports, transaction statements and account confirmations. Treating those profits as unexplained cash credit requires material showing that the broker or counterparty was tainted; no such material was identified. The preponderance-of-probabilities assessment distinguished alleged pre-arranged reversal trades involving loss-making entities from profitable trades with no identified loss-making counterparty. The trades were accepted as genuine, resulting in deletion of the unexplained cash credit addition and the consequential alleged commission expenditure addition under Section 69C.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
