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...
Disallowance on account of interest paid on delayed payment of TDS - as the tax deducted at source (TDS) is not in the nature of the income tax which is required to be paid on profits & gains chargeable to tax u/s. 28 of the Act and thus not disallowable u/s. 40(a)(ii) of the Act, the consequent the interest paid u/s. 201(1A) of the Act upon late payment of TDS also cannot be disallowed u/s. 40(a)(ii) of the Act. - AT
Disallowance on account of interest paid on delayed payment of TDS - as the tax deducted at source (TDS) is not in the nature of the income tax which is required to be paid on profits & gains chargeable to tax u/s. 28 of the Act and thus not disallowable u/s. 40(a)(ii) of the Act, the consequent the interest paid u/s. 201(1A) of the Act upon late payment of TDS also cannot be disallowed u/s. 40(a)(ii) of the Act. - AT
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