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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Accumulated charitable income validly set aside under the pre-amendment section 11(2) regime remained available for application in the year immediately following the five-year accumulation period. The Finance Act 2022 omission of that additional utilisation year operated prospectively and did not curtail rights attached to accumulations made earlier. Accordingly, application in financial year 2022-23 of income accumulated in financial year 2016-17 was not deemed taxable income for assessment year 2023-24. Return-processing adjustments cannot disallow such a claim where eligibility depends on reconciling records and resolving debatable questions concerning statutory interpretation and the amendment's temporal operation.
Accumulated charitable income validly set aside under the pre-amendment section 11(2) regime remained available for application in the year immediately following the five-year accumulation period. The Finance Act 2022 omission of that additional utilisation year operated prospectively and did not curtail rights attached to accumulations made earlier. Accordingly, application in financial year 2022-23 of income accumulated in financial year 2016-17 was not deemed taxable income for assessment year 2023-24. Return-processing adjustments cannot disallow such a claim where eligibility depends on reconciling records and resolving debatable questions concerning statutory interpretation and the amendment's temporal operation.
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