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 of provision of CSR u/s 115JB - provision made for CSR - In the present case, how the amount ear-marked for spending towards the CSR obligation will be spent is “not certain”, “clear” or “definitely known”. At best, it is just an amount which has been set aside for being spent towards Corporate Social Responsibility but without any further certainty of its end-use. Thus, it cannot be said that the liability is an ascertained liability. - AT
Disallowance of provision of CSR u/s 115JB - provision made for CSR - In the present case, how the amount ear-marked for spending towards the CSR obligation will be spent is “not certain”, “clear” or “definitely known”. At best, it is just an amount which has been set aside for being spent towards Corporate Social Responsibility but without any further certainty of its end-use. Thus, it cannot be said that the liability is an ascertained liability. - AT
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