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...
Section 194H does not apply to stockists' trade margins where pharmaceutical supplies are on a principal-to-principal basis; the margin is ordinary resale profit, not commission, so no default under section 201 arises on that count. ESOP/ESBP perquisite taxation under section 17(2)(vi) arises only on exercise of the option and allotment or transfer of shares; withholding under section 192 cannot be triggered at grant or mere accounting recognition. Delayed payment interest to MSMEs, being compensation for late sale consideration and not interest on borrowed money or debt, falls outside section 194A; where the expenditure was voluntarily disallowed, a further section 201 default consequence was unsustainable.
Section 194H does not apply to stockists' trade margins where pharmaceutical supplies are on a principal-to-principal basis; the margin is ordinary resale profit, not commission, so no default under section 201 arises on that count. ESOP/ESBP perquisite taxation under section 17(2)(vi) arises only on exercise of the option and allotment or transfer of shares; withholding under section 192 cannot be triggered at grant or mere accounting recognition. Delayed payment interest to MSMEs, being compensation for late sale consideration and not interest on borrowed money or debt, falls outside section 194A; where the expenditure was voluntarily disallowed, a further section 201 default consequence was unsustainable.
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