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...
Internal comparable pricing for captive power transfers was accepted where the same consuming units bought electricity from State distribution companies in the same market and period, resulting in deletion of transfer-pricing adjustments. Exempt-income disallowance was confined to dividend-yielding investments, and MAT adjustments required an independent determination of expenditure from the accounts. Expansion-related operating costs remained revenue expenditure unless directly attributable to acquiring or installing capital assets. Captive rail systems qualified as infrastructure facilities for section 80-IA, while common costs required expenditure-based allocation supported by a nexus. Incentives linked to capital investment and expansion were treated as capital receipts and excluded from book profit. The notes also address investment allowance, additional depreciation, bad debts, leave encashment, and specified MAT adjustments.
Internal comparable pricing for captive power transfers was accepted where the same consuming units bought electricity from State distribution companies in the same market and period, resulting in deletion of transfer-pricing adjustments. Exempt-income disallowance was confined to dividend-yielding investments, and MAT adjustments required an independent determination of expenditure from the accounts. Expansion-related operating costs remained revenue expenditure unless directly attributable to acquiring or installing capital assets. Captive rail systems qualified as infrastructure facilities for section 80-IA, while common costs required expenditure-based allocation supported by a nexus. Incentives linked to capital investment and expansion were treated as capital receipts and excluded from book profit. The notes also address investment allowance, additional depreciation, bad debts, leave encashment, and specified MAT adjustments.
Note: It is a system-generated summary and is for quick reference only.
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