Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
Intra-group management-fee transfer pricing adjustments cannot be sustained where the issue has consistently been resolved in the taxpayer's favour on materially similar facts in earlier years. Tax refunds from customs and VAT/GST are balance-sheet items rather than income; any return-processing adjustment treating them as income requires factual verification and consequential relief under law. Claimed short credit for tax deducted at source must be verified after giving the taxpayer an opportunity to substantiate the claim. Interest charged under the applicable provisions requires recomputation and a clear section-wise bifurcation to enable verification of its correctness. The management-fee adjustment was deleted, while the remaining matters required verification or recomputation.
Intra-group management-fee transfer pricing adjustments cannot be sustained where the issue has consistently been resolved in the taxpayer's favour on materially similar facts in earlier years. Tax refunds from customs and VAT/GST are balance-sheet items rather than income; any return-processing adjustment treating them as income requires factual verification and consequential relief under law. Claimed short credit for tax deducted at source must be verified after giving the taxpayer an opportunity to substantiate the claim. Interest charged under the applicable provisions requires recomputation and a clear section-wise bifurcation to enable verification of its correctness. The management-fee adjustment was deleted, while the remaining matters required verification or recomputation.
Note: It is a system-generated summary and is for quick reference only.
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