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...
Correct head of income - sale of land - “capital gains” or “business income” - In the present case, undisputedly the appellant had made a distinction between those lands which are stock in trade and those lands which are held by investment - none of the factors considered by the AO can militate against the claim of the appellant that it is an investment and the profit arising out of the sale of this land is assessable to tax under the head “capital gains” - AT
Correct head of income - sale of land - “capital gains” or “business income” - In the present case, undisputedly the appellant had made a distinction between those lands which are stock in trade and those lands which are held by investment - none of the factors considered by the AO can militate against the claim of the appellant that it is an investment and the profit arising out of the sale of this land is assessable to tax under the head “capital gains” - AT
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