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...
Interest on inter-corporate deposits was treated as accrued because no new evidence rebutted the appellate finding. Disallowance relating to investment in a limited liability partnership under section 14A and rule 8D was likewise sustained for lack of contrary material. The genuineness of loans alleged to be connected with bank-related kickbacks requires verification of the final Special CBI Court proceedings and their effect on the transactions; that issue was remanded without a merits finding. Capital losses on unquoted-share sales were accepted where valuation followed the book value method under rule 11UA read with section 50CA, no specific defect in the valuer's report was identified, and no registered-valuer reference was made.
Interest on inter-corporate deposits was treated as accrued because no new evidence rebutted the appellate finding. Disallowance relating to investment in a limited liability partnership under section 14A and rule 8D was likewise sustained for lack of contrary material. The genuineness of loans alleged to be connected with bank-related kickbacks requires verification of the final Special CBI Court proceedings and their effect on the transactions; that issue was remanded without a merits finding. Capital losses on unquoted-share sales were accepted where valuation followed the book value method under rule 11UA read with section 50CA, no specific defect in the valuer's report was identified, and no registered-valuer reference was made.
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