Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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 income under the mercantile system was held taxable in AY 2007-08 on accrual basis because the assessee, having followed that method, had to bring the entire accrued amount to tax in that year and produced no corroborative material showing that accrual had been deferred by litigation or other valid reason. The Tribunal also upheld reopening under section 147, holding that the original assessment had not examined the balance accrued interest and that information from remand proceedings constituted tangible material; the plea of mere change of opinion therefore failed. To avoid double taxation, it approved verification and rectification in AY 2009-10 if the amount had been declared there.
Interest income under the mercantile system was held taxable in AY 2007-08 on accrual basis because the assessee, having followed that method, had to bring the entire accrued amount to tax in that year and produced no corroborative material showing that accrual had been deferred by litigation or other valid reason. The Tribunal also upheld reopening under section 147, holding that the original assessment had not examined the balance accrued interest and that information from remand proceedings constituted tangible material; the plea of mere change of opinion therefore failed. To avoid double taxation, it approved verification and rectification in AY 2009-10 if the amount had been declared there.
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