Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Receipts from ancillary services connected with software licensing are considered in relation to their characterisation as fees for technical services and deemed accrual of income in India under section 9(1)(vi). The note records that the Tribunal's approach for a later assessment year relied on the Supreme Court's Engineering Analysis decision, whose review was subsequently dismissed. It further notes that no substantial question of law arose from the challenged order.
Receipts from ancillary services connected with software licensing are considered in relation to their characterisation as fees for technical services and deemed accrual of income in India under section 9(1)(vi). The note records that the Tribunal's approach for a later assessment year relied on the Supreme Court's Engineering Analysis decision, whose review was subsequently dismissed. It further notes that no substantial question of law arose from the challenged order.
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