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...
Composite letting of commercial premises, amenities and permanently embedded fixtures is assessable as income from house property where the ancillary agreements are integral to and co-terminus with the principal leave-and-licence arrangement. The substance of the arrangement and the parties' dominant intention prevail over separate documentation or apportionment of consideration; amenities not independently exploitable remain part of the integrated commercial unit. Such assessment permits the standard deduction for house property income. Interest on a refinanced loan remains deductible where it replaces acquisition-related borrowing, the funds are traceable to property acquisition, and no diversion to a non-qualifying purpose is established, subject to arithmetical verification of utilisation.
Composite letting of commercial premises, amenities and permanently embedded fixtures is assessable as income from house property where the ancillary agreements are integral to and co-terminus with the principal leave-and-licence arrangement. The substance of the arrangement and the parties' dominant intention prevail over separate documentation or apportionment of consideration; amenities not independently exploitable remain part of the integrated commercial unit. Such assessment permits the standard deduction for house property income. Interest on a refinanced loan remains deductible where it replaces acquisition-related borrowing, the funds are traceable to property acquisition, and no diversion to a non-qualifying purpose is established, subject to arithmetical verification of utilisation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
