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...
Exemption claimed u/s.10(23B) - Mandatory approval from Khadi and Village Industries Commission - approval was granted for more than three assessment years and therefore the condition for claiming exemption u/s. 10(23B) was not fulfilled - It is pertinent to note that the time period for which the certificate has to be granted is not within the control of the assessee. In any case it is only a technical violation for which the assessee could not be penalized by denying the exemption otherwise allowable to the assessee. Thus, we hold that the assessee is entitled for exemption u/s. 10(23B) of the Act. - AT
Exemption claimed u/s.10(23B) - Mandatory approval from Khadi and Village Industries Commission - approval was granted for more than three assessment years and therefore the condition for claiming exemption u/s. 10(23B) was not fulfilled - It is pertinent to note that the time period for which the certificate has to be granted is not within the control of the assessee. In any case it is only a technical violation for which the assessee could not be penalized by denying the exemption otherwise allowable to the assessee. Thus, we hold that the assessee is entitled for exemption u/s. 10(23B) of the Act. - AT
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