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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Interest expenditure may be deducted against dividend income only to the extent that borrowed funds have a direct nexus with investments generating that income; the extent of such nexus is a factual determination and the balance interest cannot be deducted without supporting evidence. No notional interest is taxable on refundable security deposits for employee residential premises where the deposits serve business purposes and generate no actual income. The High Court also rejected the Revenue's challenges concerning deduction for a new industrial undertaking in existing factory premises and interest and trial-run overheads relating to new machinery, following prior decisions. Questions on closing-stock valuation, including excise-duty treatment, were answered under an earlier High Court ruling.
Interest expenditure may be deducted against dividend income only to the extent that borrowed funds have a direct nexus with investments generating that income; the extent of such nexus is a factual determination and the balance interest cannot be deducted without supporting evidence. No notional interest is taxable on refundable security deposits for employee residential premises where the deposits serve business purposes and generate no actual income. The High Court also rejected the Revenue's challenges concerning deduction for a new industrial undertaking in existing factory premises and interest and trial-run overheads relating to new machinery, following prior decisions. Questions on closing-stock valuation, including excise-duty treatment, were answered under an earlier High Court ruling.
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