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...
Characterization of income - subscriptions received from the public at large under a collective investment scheme - assessee shown these as income in P/L account - it is clear that on general principles also such subscription cannot possibly be treated as income and it would not be possible to go only by the treatment of such subscriptions in the hands of accounts of the assessee itself - receipts in question were capital receipts and not income.
Characterization of income - subscriptions received from the public at large under a collective investment scheme - assessee shown these as income in P/L account - it is clear that on general principles also such subscription cannot possibly be treated as income and it would not be possible to go only by the treatment of such subscriptions in the hands of accounts of the assessee itself - receipts in question were capital receipts and not income.
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