Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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...
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Scientific warranty provisions for automotive products may be deductible where liability arises on each sale and the provision is consistently estimated from historical experience, applying accrual and matching principles. Grossed-up withholding tax borne under an intellectual-property royalty agreement may form part of royalty consideration where the payer contractually assumes the foreign recipient's tax liability. For approved in-house research and development facilities, weighted deduction may cover eligible scientific-research expenditure actually incurred and cannot be restricted solely to the amount certified by DSIR. A challenge to the prescribed format of a notice under section 143(2) was rejected. The reported appeals were partly allowed, with the three expenditure disallowances deleted.
Scientific warranty provisions for automotive products may be deductible where liability arises on each sale and the provision is consistently estimated from historical experience, applying accrual and matching principles. Grossed-up withholding tax borne under an intellectual-property royalty agreement may form part of royalty consideration where the payer contractually assumes the foreign recipient's tax liability. For approved in-house research and development facilities, weighted deduction may cover eligible scientific-research expenditure actually incurred and cannot be restricted solely to the amount certified by DSIR. A challenge to the prescribed format of a notice under section 143(2) was rejected. The reported appeals were partly allowed, with the three expenditure disallowances deleted.
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