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...
Payment received under an employer's ERS/VRS scheme, being ex gratia compensation on cessation of employment and not shown to arise from any enforceable obligation for termination, was held not taxable as profits in lieu of salary under section 17(3)(i). Following its earlier decision on similar facts, the Tribunal found no contrary material from the Revenue and held that the addition sustained by the appellate authority was unsustainable. The addition was directed to be deleted.
Payment received under an employer's ERS/VRS scheme, being ex gratia compensation on cessation of employment and not shown to arise from any enforceable obligation for termination, was held not taxable as profits in lieu of salary under section 17(3)(i). Following its earlier decision on similar facts, the Tribunal found no contrary material from the Revenue and held that the addition sustained by the appellate authority was unsustainable. The addition was directed to be deleted.
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