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...
Addition u/s 43CA - difference between agreement value of the flats and market value determined by the DVO - in the light of reasoning given for insertion of the proviso and exposition by the Tribunal for retrospective application of the said proviso, have no hesitation in holding that the proviso to sub-section (1) to section 43CA and the subsequent amendment thereto relates back to the date on which the said section was made effective i.e. 01/4/2014. - AT
Addition u/s 43CA - difference between agreement value of the flats and market value determined by the DVO - in the light of reasoning given for insertion of the proviso and exposition by the Tribunal for retrospective application of the said proviso, have no hesitation in holding that the proviso to sub-section (1) to section 43CA and the subsequent amendment thereto relates back to the date on which the said section was made effective i.e. 01/4/2014. - AT
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