Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
Interpretation of Section 44BB and 44DA - bifurcation between the supply of software as well as ancillary services such as maintenance and installation - It is question of fact - CIT directed to determine income on account of receipts from provision of software enabled solutions to the oil and gas industry along with providing annual maintenance services of the software - CIT to assess the Petitioner’s income and tax payable thereon by first determining the nature of the income/receipts in the hands of the assessee in light of the observations made in this judgment. - HC
Interpretation of Section 44BB and 44DA - bifurcation between the supply of software as well as ancillary services such as maintenance and installation - It is question of fact - CIT directed to determine income on account of receipts from provision of software enabled solutions to the oil and gas industry along with providing annual maintenance services of the software - CIT to assess the Petitioner’s income and tax payable thereon by first determining the nature of the income/receipts in the hands of the assessee in light of the observations made in this judgment. - HC
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