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...
Interest provision based on an arbitral award was disallowed because the Supreme Court's setting aside of that award extinguished the underlying liability, so the claim had to be reconsidered on the footing that no such interest was payable. Expenditure on gifts, boarding, lodging and allied arrangements for a General Body Meeting was held to be business expenditure under a purposive reading of section 37, since convening such a meeting was a statutory requirement and the Assessing Officer could not reject the claim merely as excessive once its business purpose was established. The Tribunal's allowance of that expenditure was affirmed, while the interest provision deduction was rejected.
Interest provision based on an arbitral award was disallowed because the Supreme Court's setting aside of that award extinguished the underlying liability, so the claim had to be reconsidered on the footing that no such interest was payable. Expenditure on gifts, boarding, lodging and allied arrangements for a General Body Meeting was held to be business expenditure under a purposive reading of section 37, since convening such a meeting was a statutory requirement and the Assessing Officer could not reject the claim merely as excessive once its business purpose was established. The Tribunal's allowance of that expenditure was affirmed, while the interest provision deduction was rejected.
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