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...
Disallowance of expenditure u/s. 37(1) - professional charges paid - quantum of allowance - There is no power to AO to reduce the claim, whereas he can examine whether the amount can be allowed or not in full. Since the restrictions u/s. 37(1) are not applicable, the whole of the amount claimed is to be allowed as the expenditure is not proved to be personal or capital in nature.
Disallowance of expenditure u/s. 37(1) - professional charges paid - quantum of allowance - There is no power to AO to reduce the claim, whereas he can examine whether the amount can be allowed or not in full. Since the restrictions u/s. 37(1) are not applicable, the whole of the amount claimed is to be allowed as the expenditure is not proved to be personal or capital in nature.
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