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...
Contribution paid to an insurer under a leave encashment scheme is treated as actual business expenditure, distinct from a mere provision, and CSR spending mandated under port guidelines is viewed as business-linked, with the statutory disallowance operating prospectively. Disputed enhanced estate rentals are not taxable as real income where recoverability remains uncertain, and port infrastructure such as docks, sea walls, piers and railway assets may qualify as plant under the functional test for depreciation. Consequential disallowance for short deduction of tax at source falls once the underlying TDS default is deleted, and employee welfare and labour-related contributions are allowable where made for commercial expediency.
Contribution paid to an insurer under a leave encashment scheme is treated as actual business expenditure, distinct from a mere provision, and CSR spending mandated under port guidelines is viewed as business-linked, with the statutory disallowance operating prospectively. Disputed enhanced estate rentals are not taxable as real income where recoverability remains uncertain, and port infrastructure such as docks, sea walls, piers and railway assets may qualify as plant under the functional test for depreciation. Consequential disallowance for short deduction of tax at source falls once the underlying TDS default is deleted, and employee welfare and labour-related contributions are allowable where made for commercial expediency.
Note: It is a system-generated summary and is for quick reference only.
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