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 u/s 40(a)(ia) of Wharfage charges - Wharfage charges paid by assessee are charges which facilitate the loading / unloading of goods at waterfront - no use of land but even if it was held that there is any use of land, then the same was incidental - cannot be equated to be a charge for ‘rent’ for use of water - No TDS u/s 194I - allowed as deduction u/s 37(1)
Disallowance u/s 40(a)(ia) of Wharfage charges - Wharfage charges paid by assessee are charges which facilitate the loading / unloading of goods at waterfront - no use of land but even if it was held that there is any use of land, then the same was incidental - cannot be equated to be a charge for ‘rent’ for use of water - No TDS u/s 194I - allowed as deduction u/s 37(1)
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