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...
Penalty 271(1)(c) - deduction of interest out of ‘income from other sources’ - The AO has admitted the claim of interest expenditure to the extent of interest income and therefore one cannot definitely say that interest expenditure was not utilized for the purpose of earning interests - The disallowance of excess expenditure over and above similar income generated, cannot invite penal action in the form of penalty
Penalty 271(1)(c) - deduction of interest out of ‘income from other sources’ - The AO has admitted the claim of interest expenditure to the extent of interest income and therefore one cannot definitely say that interest expenditure was not utilized for the purpose of earning interests - The disallowance of excess expenditure over and above similar income generated, cannot invite penal action in the form of penalty
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