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 of interest on unsecured loan taken which is 100% subsidiary of the assessee - addition on the ground as it is not incurred for the purpose of assessee’s business though the said borrowings were utilised for investments in subsidiaries which is part of business purpose of the assessee company - the interest on unsecured loan taken is an allowable expenditure. - AT
Disallowance of interest on unsecured loan taken which is 100% subsidiary of the assessee - addition on the ground as it is not incurred for the purpose of assessee’s business though the said borrowings were utilised for investments in subsidiaries which is part of business purpose of the assessee company - the interest on unsecured loan taken is an allowable expenditure. - AT
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