Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Bad-debt deduction for share-broking client dues may be claimed where outstanding client balances are treated as irrecoverable and written off in the accounts. Under amended section 36(1)(vii), actual irrecoverability need not be established. Continuing transactions or payments by clients do not preclude the claim where the broker follows a consistent settlement pattern under which clients pay agreed amounts and residual balances are written off. Client receivables qualify as debts when brokerage included in those receivables has been taken into account in computing income. The disallowance of the written-off client dues was deleted and the deduction sustained.
Bad-debt deduction for share-broking client dues may be claimed where outstanding client balances are treated as irrecoverable and written off in the accounts. Under amended section 36(1)(vii), actual irrecoverability need not be established. Continuing transactions or payments by clients do not preclude the claim where the broker follows a consistent settlement pattern under which clients pay agreed amounts and residual balances are written off. Client receivables qualify as debts when brokerage included in those receivables has been taken into account in computing income. The disallowance of the written-off client dues was deleted and the deduction sustained.
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