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...
Marketing expenditure supported only by self-made vouchers may be disallowed where third-party evidence is absent, but a complete disallowance may be inappropriate when the expenditure is modest relative to turnover, relates to client visits and outstation costs, and audited books contain no adverse comments. The discussion notes that a restricted disallowance was sustained. It further explains that insufficient substantiation of an expenditure claim does not itself establish misreporting under section 270A unless a statutory category, such as misrepresentation, suppression of facts, lack of evidence, or a false book entry, is identified. The related misreporting penalty was deleted.
Marketing expenditure supported only by self-made vouchers may be disallowed where third-party evidence is absent, but a complete disallowance may be inappropriate when the expenditure is modest relative to turnover, relates to client visits and outstation costs, and audited books contain no adverse comments. The discussion notes that a restricted disallowance was sustained. It further explains that insufficient substantiation of an expenditure claim does not itself establish misreporting under section 270A unless a statutory category, such as misrepresentation, suppression of facts, lack of evidence, or a false book entry, is identified. The related misreporting penalty was deleted.
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