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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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Notional rental income was deleted because the earlier rent memorandum had been superseded by an operative agreement, independently confirmed by the tenant and supported by invoices, banking records and tax statements. Booking advances did not constitute ceased or bogus liabilities merely because they remained outstanding; sale and transfer documentation supported their continuity. An opening loan balance could not be treated as unexplained cash credit because no credit arose during the relevant year. A debt written off in the accounts qualified for deduction without proof of actual irrecoverability. Supported repairs and routine business expenses were allowed, but interest on tax deducted at source remained disallowed. Penalty was deleted while the assessment's jurisdiction remained under challenge, subject to lawful reinitiation after the writ petition's disposal.
Notional rental income was deleted because the earlier rent memorandum had been superseded by an operative agreement, independently confirmed by the tenant and supported by invoices, banking records and tax statements. Booking advances did not constitute ceased or bogus liabilities merely because they remained outstanding; sale and transfer documentation supported their continuity. An opening loan balance could not be treated as unexplained cash credit because no credit arose during the relevant year. A debt written off in the accounts qualified for deduction without proof of actual irrecoverability. Supported repairs and routine business expenses were allowed, but interest on tax deducted at source remained disallowed. Penalty was deleted while the assessment's jurisdiction remained under challenge, subject to lawful reinitiation after the writ petition's disposal.
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