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...
Foreign exchange gain from realization of export proceeds for IT/ITES services rendered to associated enterprises was treated as operating income under TNMM, because it arose on revenue account in the normal course of business; the Assessing Officer was directed to verify this linkage, and the remaining transfer pricing grounds were left academic. Donation to Odisha State Disaster Management Authority was held eligible for deduction under section 80G despite being part of CSR expenditure, as there is no general bar outside the statutory exclusions. The foreign tax credit claim under section 90 was restored for verification and consequential grant in accordance with law.
Foreign exchange gain from realization of export proceeds for IT/ITES services rendered to associated enterprises was treated as operating income under TNMM, because it arose on revenue account in the normal course of business; the Assessing Officer was directed to verify this linkage, and the remaining transfer pricing grounds were left academic. Donation to Odisha State Disaster Management Authority was held eligible for deduction under section 80G despite being part of CSR expenditure, as there is no general bar outside the statutory exclusions. The foreign tax credit claim under section 90 was restored for verification and consequential grant in accordance with law.
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