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...
Section 87A does not expressly bar rebate against tax payable on short-term capital gains from listed equity shares taxed at the special rate under section 111A. Applying a plain reading of both provisions and following the cited Tribunal precedent, rebate under section 87A is available in respect of such tax liability. Denial of the claimed rebate was therefore unsustainable, and the Assessing Officers were directed to grant it.
Section 87A does not expressly bar rebate against tax payable on short-term capital gains from listed equity shares taxed at the special rate under section 111A. Applying a plain reading of both provisions and following the cited Tribunal precedent, rebate under section 87A is available in respect of such tax liability. Denial of the claimed rebate was therefore unsustainable, and the Assessing Officers were directed to grant it.
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