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 56(2)(viib) does not apply where shares are issued as non-cash consideration for acquiring a business undertaking, because no money is received; the share-premium addition was deleted. Bad-debt deductions were allowed where receivables had been taxed earlier and were written off, including student-fee receivables supported by detailed records. Section 14A disallowance was deleted in the absence of exempt income. Reversal of advance or unearned fees did not attract sections 41(1) or 28(iv) where no earlier deduction or benefit arose, and acknowledged creditor liabilities were not treated as ceased. Loan processing charges were allowable as interest-related business expenditure. TDS-related relief depended on the payee offering income to tax; other disallowances were sustained, restricted, or remanded according to the applicable rules and evidence of liability crystallisation.
Section 56(2)(viib) does not apply where shares are issued as non-cash consideration for acquiring a business undertaking, because no money is received; the share-premium addition was deleted. Bad-debt deductions were allowed where receivables had been taxed earlier and were written off, including student-fee receivables supported by detailed records. Section 14A disallowance was deleted in the absence of exempt income. Reversal of advance or unearned fees did not attract sections 41(1) or 28(iv) where no earlier deduction or benefit arose, and acknowledged creditor liabilities were not treated as ceased. Loan processing charges were allowable as interest-related business expenditure. TDS-related relief depended on the payee offering income to tax; other disallowances were sustained, restricted, or remanded according to the applicable rules and evidence of liability crystallisation.
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