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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Gains from cancellation or early settlement of forward foreign exchange contracts entered solely to hedge debt investments retain the capital character of the underlying capital assets. The contracts were restricted by the underlying foreign-exchange exposure, could not subsist independently after disposal of the securities, and their settlement extinguished contractual rights and obligations, constituting a transfer. Accordingly, the gain was treated under Capital Gains rather than Income from Other Sources. Consistent coordinate Bench decisions in the same taxpayer's case remained binding despite pending High Court appeals, absent any stay or reversal, and were followed. Penalty-initiation objections were described as premature.
Gains from cancellation or early settlement of forward foreign exchange contracts entered solely to hedge debt investments retain the capital character of the underlying capital assets. The contracts were restricted by the underlying foreign-exchange exposure, could not subsist independently after disposal of the securities, and their settlement extinguished contractual rights and obligations, constituting a transfer. Accordingly, the gain was treated under Capital Gains rather than Income from Other Sources. Consistent coordinate Bench decisions in the same taxpayer's case remained binding despite pending High Court appeals, absent any stay or reversal, and were followed. Penalty-initiation objections were described as premature.
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