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...
Exemption u/s 11 - advancing a loan to another charitable trust - nothing has been brought on record to establish that the common trustees have substantial interest in the other trust - the amount advanced cannot be held to be in violation of Sec.13(1)(d) - Sec.11(5) cannot be applied to present facts as the money advanced is not an investment but a loan - Exemption cannot be denied - AT
Exemption u/s 11 - advancing a loan to another charitable trust - nothing has been brought on record to establish that the common trustees have substantial interest in the other trust - the amount advanced cannot be held to be in violation of Sec.13(1)(d) - Sec.11(5) cannot be applied to present facts as the money advanced is not an investment but a loan - Exemption cannot be denied - AT
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