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) - payment of pigmy commission had direct nexus with the business income of the assessee on which deduction u/s 80P(2)(a)(i) was claimed - If the disallowance u/s.40(a)(i) results in increase in income which would otherwise go to enhance the income on which the Assessee is eligible for deduction, then the CBDT Circular would be applicable and deduction will be allowable
Disallowance u/s 40(a)(ia) - payment of pigmy commission had direct nexus with the business income of the assessee on which deduction u/s 80P(2)(a)(i) was claimed - If the disallowance u/s.40(a)(i) results in increase in income which would otherwise go to enhance the income on which the Assessee is eligible for deduction, then the CBDT Circular would be applicable and deduction will be allowable
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