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 earned on fixed deposits compulsorily created under subsidy sanction conditions for a cold chain facility was held to have a direct nexus with the business activity, not to be income from other sources. On that basis, the Tribunal treated the interest as business income and held it eligible for deduction under section 80IB(11), deleting the disallowance. It also found the additions for savings bank interest and income-tax refund interest factually unsustainable, as no savings account existed in the assessee's name and no deduction had been claimed for refund interest. Those additions were deleted, and the appeal was allowed.
Interest earned on fixed deposits compulsorily created under subsidy sanction conditions for a cold chain facility was held to have a direct nexus with the business activity, not to be income from other sources. On that basis, the Tribunal treated the interest as business income and held it eligible for deduction under section 80IB(11), deleting the disallowance. It also found the additions for savings bank interest and income-tax refund interest factually unsustainable, as no savings account existed in the assessee's name and no deduction had been claimed for refund interest. Those additions were deleted, and the appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
