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...
Taxability of shares premium u/s 56(2)(viib) - AO was required to undertake the exercise of fact finding by determining the FMV of the Shares in question as per Explanation to Section 56(2)(viib) - remanded back to AO because such exercise not having been done - the Assessee will be free to raise all factual and legal contentions including treating said amount as 'gift' from mother to daughter.
Taxability of shares premium u/s 56(2)(viib) - AO was required to undertake the exercise of fact finding by determining the FMV of the Shares in question as per Explanation to Section 56(2)(viib) - remanded back to AO because such exercise not having been done - the Assessee will be free to raise all factual and legal contentions including treating said amount as 'gift' from mother to daughter.
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