Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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...
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Commission expenditure claimed against income from other sources may be deductible where evidence establishes a direct commercial nexus between the facilitation services and the commission earned. Customer purchase orders and sales records may demonstrate the payee firm's customer relationships, overlapping product trade, infrastructure and network. Where the payment is taxed in the recipient's hands and actual payment through banking channels is undisputed, such material can support admission of additional evidence and allowance of the deduction under section 57.
Commission expenditure claimed against income from other sources may be deductible where evidence establishes a direct commercial nexus between the facilitation services and the commission earned. Customer purchase orders and sales records may demonstrate the payee firm's customer relationships, overlapping product trade, infrastructure and network. Where the payment is taxed in the recipient's hands and actual payment through banking channels is undisputed, such material can support admission of additional evidence and allowance of the deduction under section 57.
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