Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Section 10B requires separate computation of export profits for each eligible software-export undertaking only to quantify the deduction. That separate computation does not alter the undertaking's profit or loss for computing combined income, nor does it displace the normal rules for inter-source and inter-head set-off and carry forward of losses. Losses of a Section 10B-eligible undertaking may therefore be set off against profits of other undertakings, with any unabsorbed balance carried forward in accordance with law. The contrary denial of set-off was set aside.
Section 10B requires separate computation of export profits for each eligible software-export undertaking only to quantify the deduction. That separate computation does not alter the undertaking's profit or loss for computing combined income, nor does it displace the normal rules for inter-source and inter-head set-off and carry forward of losses. Losses of a Section 10B-eligible undertaking may therefore be set off against profits of other undertakings, with any unabsorbed balance carried forward in accordance with law. The contrary denial of set-off was set aside.
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