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 interest payment converted into FITL (Funded Interest Term Loans) - the impugned ‘funded interest term loan’ is not a loan transaction but assessee’s contract agreement with the creditor party and therefore, the CIT(A) has held that the same is not exigible to ‘actual payment’ contemplated u/s.43B of the Act. - No additions - AT
Disallowance of interest payment converted into FITL (Funded Interest Term Loans) - the impugned ‘funded interest term loan’ is not a loan transaction but assessee’s contract agreement with the creditor party and therefore, the CIT(A) has held that the same is not exigible to ‘actual payment’ contemplated u/s.43B of the Act. - No additions - AT
Note: It is a system-generated summary and is for quick reference only.