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...
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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