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...
Employee-welfare payments to educational institutions and club expenditure were treated as business expenditure where incurred wholly and exclusively for business purposes. Enabling-facility costs were characterised as revenue expenditure because no capital asset was acquired. Receipts directly connected with setting up a plant were treated as capital receipts reducible from capital work-in-progress. Depreciation on business vehicles and temporary structures was allowed, while a challenge based on additional depreciation was treated as misconceived because the relief concerned consequential differential depreciation. Bad debts, advances and claims written off were allowable. Premium amortisation on foreign-exchange forward contracts used for hedging was non-speculative, not contingent or notional. Mineral-oil exploration and drilling survey expenditure qualified for deduction under the production-sharing contract framework.
Employee-welfare payments to educational institutions and club expenditure were treated as business expenditure where incurred wholly and exclusively for business purposes. Enabling-facility costs were characterised as revenue expenditure because no capital asset was acquired. Receipts directly connected with setting up a plant were treated as capital receipts reducible from capital work-in-progress. Depreciation on business vehicles and temporary structures was allowed, while a challenge based on additional depreciation was treated as misconceived because the relief concerned consequential differential depreciation. Bad debts, advances and claims written off were allowable. Premium amortisation on foreign-exchange forward contracts used for hedging was non-speculative, not contingent or notional. Mineral-oil exploration and drilling survey expenditure qualified for deduction under the production-sharing contract framework.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
