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...
Rejection of book result u/s 145(3) - estimation of income - Deduction of depreciation from the estimated income - Depreciation should be allowable being statutory allowance where Assessing Officer has rejected the books of account and estimated the income of the assessee. However, the profit declared by the assessee in the return of income cannot be further reduced on account of partner's remuneration, interest on partner's capital and the depreciation. - AT
Rejection of book result u/s 145(3) - estimation of income - Deduction of depreciation from the estimated income - Depreciation should be allowable being statutory allowance where Assessing Officer has rejected the books of account and estimated the income of the assessee. However, the profit declared by the assessee in the return of income cannot be further reduced on account of partner's remuneration, interest on partner's capital and the depreciation. - AT
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