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...
Reopening of assessment u/s 147 - Disallowance of custom duty paid - The claim of the assessee for the custom duty is not applicable in the given facts and circumstances for the reason that the present proceedings before us are under Section 147 of the Act which cannot extend any benefit to the assessee. Accordingly, before going into the intricacies whether the assessee is eligible for the custom duty paid by it as deduction or not is not within the provisions of law. Once, a claim is not admissible, we refrain ourselves from adjudicating the issue raised by the assessee on the admissibility of custom duty paid by it. Hence, the ground of appeal of the assessee is dismissed. - AT
Reopening of assessment u/s 147 - Disallowance of custom duty paid - The claim of the assessee for the custom duty is not applicable in the given facts and circumstances for the reason that the present proceedings before us are under Section 147 of the Act which cannot extend any benefit to the assessee. Accordingly, before going into the intricacies whether the assessee is eligible for the custom duty paid by it as deduction or not is not within the provisions of law. Once, a claim is not admissible, we refrain ourselves from adjudicating the issue raised by the assessee on the admissibility of custom duty paid by it. Hence, the ground of appeal of the assessee is dismissed. - AT
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