Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
Exemption u/s 80-IC - Claim denied as no work was carried at the Baddi Unit - There is no concrete material on record which would suggest that the assessee’s claim was not genuine and no work was carried at the Baddi Unit. The fact that the assessee had one internet connection / AC or inadequate computer facilities or the fact the bank accounts were not maintained at Baddi location is only a matter of perception and nothing conclusive could be borne out of those observations. Assessee had well substantiated its claim of deduction u/s 80-I - AT
Exemption u/s 80-IC - Claim denied as no work was carried at the Baddi Unit - There is no concrete material on record which would suggest that the assessee’s claim was not genuine and no work was carried at the Baddi Unit. The fact that the assessee had one internet connection / AC or inadequate computer facilities or the fact the bank accounts were not maintained at Baddi location is only a matter of perception and nothing conclusive could be borne out of those observations. Assessee had well substantiated its claim of deduction u/s 80-I - AT
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