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...
Additions u/s 56(2)(ix) - Mesne profit / liquidated damages - Amount remained with assessee after cancellation of the said sale in terms of the decree order of the Hon’ble jurisdictional Delhi High Court - the same was in the nature of mesne profit and beyond the provisions of section 56(2)(ix) - the said section is also not applicable as the twin conditions mentioned therein have not been met on the facts - AT
Additions u/s 56(2)(ix) - Mesne profit / liquidated damages - Amount remained with assessee after cancellation of the said sale in terms of the decree order of the Hon’ble jurisdictional Delhi High Court - the same was in the nature of mesne profit and beyond the provisions of section 56(2)(ix) - the said section is also not applicable as the twin conditions mentioned therein have not been met on the facts - AT
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