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...
Capital Gains - Whether land belonged to the ''HUF'' and not to the assessee? - there was no mentioned that the land was being sold by the assessee as Karta of 'HUF' - proceeds of the sale were also deposited/retained by the assessee in his individual capacity and further the land so purchased out of the proceeds of the sale was also in the name of the assessee in individual capacity - plea that the income/capital gains should have been assessed in the name of the 'HUF' seems to be an afterthought. - AT
Capital Gains - Whether land belonged to the ''HUF'' and not to the assessee? - there was no mentioned that the land was being sold by the assessee as Karta of 'HUF' - proceeds of the sale were also deposited/retained by the assessee in his individual capacity and further the land so purchased out of the proceeds of the sale was also in the name of the assessee in individual capacity - plea that the income/capital gains should have been assessed in the name of the 'HUF' seems to be an afterthought. - AT
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