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 received on enhanced compensation was held taxable under the head "Income from Other Sources" after the post-2009 statutory scheme, with only the prescribed 50% deduction available; the claim for exemption under section 10(37) was rejected. The Tribunal followed its earlier coordinate-bench ruling and treated the amended provisions as governing the tax treatment of interest on compensation. The assessee's challenge to the reassessment, based on non-supply of recorded reasons and absence of a transfer intimation under the faceless procedure, also failed because participation in the proceedings showed no demonstrated prejudice and no incurable jurisdictional defect was established. The assessment was upheld and the appeal was dismissed.
Interest received on enhanced compensation was held taxable under the head "Income from Other Sources" after the post-2009 statutory scheme, with only the prescribed 50% deduction available; the claim for exemption under section 10(37) was rejected. The Tribunal followed its earlier coordinate-bench ruling and treated the amended provisions as governing the tax treatment of interest on compensation. The assessee's challenge to the reassessment, based on non-supply of recorded reasons and absence of a transfer intimation under the faceless procedure, also failed because participation in the proceedings showed no demonstrated prejudice and no incurable jurisdictional defect was established. The assessment was upheld and the appeal was dismissed.
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