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...
Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee's own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at dealer premises was upheld, and fresh bad debt and foreign tax credit claims were remanded. Duty drawback taxed on accrual basis was deleted on consistency.
Dividend distribution tax was held capable of being restricted to the applicable treaty rate under the dividend articles, and the MFN benefit under the India-Netherlands treaty was noted as potentially available; the matter was restored for factual verification and refund computation. AMP and research-and-training TP adjustments were deleted because those expenses were found to be for the assessee's own business and not international transactions. Royalty for non-exclusive use of technology and trademarks was treated as revenue expenditure, higher and balance additional depreciation on electrical installations was allowed, scientific research expenditure and CSR-linked qualifying donations were allowed, section 32AC relief for machinery at dealer premises was upheld, and fresh bad debt and foreign tax credit claims were remanded. Duty drawback taxed on accrual basis was deleted on consistency.
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