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 54 capital-gains exemption remains available where capital gains are invested in a new residential house within the prescribed period, even if the unutilised amount was not deposited in the Capital Gains Account Scheme before the return-filing due date. Treating section 54 as a beneficial provision, the Tribunal regarded the deposit requirement as procedural where the substantive investment condition was met. The taxpayer's share in the jointly acquired property exceeded the capital gain and the purchase occurred before the extended return-filing due date. Accordingly, the section 54 deduction was allowed and the disallowance was deleted.
Section 54 capital-gains exemption remains available where capital gains are invested in a new residential house within the prescribed period, even if the unutilised amount was not deposited in the Capital Gains Account Scheme before the return-filing due date. Treating section 54 as a beneficial provision, the Tribunal regarded the deposit requirement as procedural where the substantive investment condition was met. The taxpayer's share in the jointly acquired property exceeded the capital gain and the purchase occurred before the extended return-filing due date. Accordingly, the section 54 deduction was allowed and the disallowance was deleted.
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