Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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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