Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
The ITAT upheld deduction under section 10AA for three SEZ undertakings and for onsite software development profits, and rejected the section 14A disallowance because no exempt income was earned. It also sustained depreciation on goodwill and exclusion of Australian fringe benefit tax from book profit under section 115JB. Foreign tax credit for Japan taxes was allowed, while taxes not eligible for treaty credit were held deductible under section 37(1). The assessee's challenge to allocation of interest cost to section 10AA units failed. Exchange fluctuation was to be split between capital and revenue components, with only the revenue part taxed. Delisting expenses were restored for want of evidence, and prior period expense and foreign tax credit recomputation issues were remanded.
The ITAT upheld deduction under section 10AA for three SEZ undertakings and for onsite software development profits, and rejected the section 14A disallowance because no exempt income was earned. It also sustained depreciation on goodwill and exclusion of Australian fringe benefit tax from book profit under section 115JB. Foreign tax credit for Japan taxes was allowed, while taxes not eligible for treaty credit were held deductible under section 37(1). The assessee's challenge to allocation of interest cost to section 10AA units failed. Exchange fluctuation was to be split between capital and revenue components, with only the revenue part taxed. Delisting expenses were restored for want of evidence, and prior period expense and foreign tax credit recomputation issues were remanded.
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