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...
Debatable employees' PF/ESI contribution claims could not be disallowed through summary adjustment where, on the intimation date, jurisdictional High Court authority supported allowability of payments made before the return-filing due date. Retention of that adjustment in scrutiny without independent examination remained challengeable in appeal, and the AY 2018-19 disallowance was deleted. For exempt-income expenditure, only investments that actually yielded exempt income during the relevant year could be considered under section 14A and Rule 8D; no additional disallowance survived beyond the voluntary amount, and the related book-profit adjustment was also deleted for AY 2018-19. Charitable-contribution deductions were remitted solely to verify payment receipts and genuineness.
Debatable employees' PF/ESI contribution claims could not be disallowed through summary adjustment where, on the intimation date, jurisdictional High Court authority supported allowability of payments made before the return-filing due date. Retention of that adjustment in scrutiny without independent examination remained challengeable in appeal, and the AY 2018-19 disallowance was deleted. For exempt-income expenditure, only investments that actually yielded exempt income during the relevant year could be considered under section 14A and Rule 8D; no additional disallowance survived beyond the voluntary amount, and the related book-profit adjustment was also deleted for AY 2018-19. Charitable-contribution deductions were remitted solely to verify payment receipts and genuineness.
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