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...
Absence of separate books for the LIC commission activity justified only an estimated deduction, and the existing disallowance was upheld because the allowed amount broadly matched the admissible estimate on gross commission. Margin shortfall charges paid to NCDEX were treated as compensatory, not as expenditure for an offence or prohibited act, so they were held allowable as business expenditure and the disallowance was deleted. An ad hoc interest disallowance on borrowed funds was also deleted because the borrowings were shown to be absorbed in business assets and receivables, no specific non-business advance was identified, and the books were not found defective.
Absence of separate books for the LIC commission activity justified only an estimated deduction, and the existing disallowance was upheld because the allowed amount broadly matched the admissible estimate on gross commission. Margin shortfall charges paid to NCDEX were treated as compensatory, not as expenditure for an offence or prohibited act, so they were held allowable as business expenditure and the disallowance was deleted. An ad hoc interest disallowance on borrowed funds was also deleted because the borrowings were shown to be absorbed in business assets and receivables, no specific non-business advance was identified, and the books were not found defective.
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