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...
Protective additions for alleged secret commission receipts cannot survive after deletion of corresponding substantive additions in the hands of the alleged real beneficiary. The Tribunal's reasoning, as reported, also notes that the Commissioner (Appeals) found no substantive evidence supporting the alleged receipts, and that the taxpayer's position for relevant assessment years was supported by the cited High Court decision. Consequently, the protective additions were unsustainable and the Revenue's appeals were dismissed.
Protective additions for alleged secret commission receipts cannot survive after deletion of corresponding substantive additions in the hands of the alleged real beneficiary. The Tribunal's reasoning, as reported, also notes that the Commissioner (Appeals) found no substantive evidence supporting the alleged receipts, and that the taxpayer's position for relevant assessment years was supported by the cited High Court decision. Consequently, the protective additions were unsustainable and the Revenue's appeals were dismissed.
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