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...
Deduction u/s 54 - LTCG invested in buying two residential units - the assessee would only entitle to the benefit of section 54, 1) if the assessee invested the LTCG amount for buying one residential house or 2) if the assessee purchased one residential house which was made after merger of two residential units already amalgamated and were in existence as one residential unit - However the assessee is not entitled to benefit of LTCG invested in buying two residential units and thereafter converting the said two residential units as one. - AT
Deduction u/s 54 - LTCG invested in buying two residential units - the assessee would only entitle to the benefit of section 54, 1) if the assessee invested the LTCG amount for buying one residential house or 2) if the assessee purchased one residential house which was made after merger of two residential units already amalgamated and were in existence as one residential unit - However the assessee is not entitled to benefit of LTCG invested in buying two residential units and thereafter converting the said two residential units as one. - AT
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