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...
Determination of income u/s 44 - Taxing the income arising on account of shareholders profits - where the assessee company was engaged only in life insurance business and was not carrying on any other business, surplus or deficit as per shareholders account is to be aggregated with surplus or deficit with policyholders account for the purpose of determining the Profit & Loss Account of an assessee engaged in life insurance business u/s 44 of the Act. - AT
Determination of income u/s 44 - Taxing the income arising on account of shareholders profits - where the assessee company was engaged only in life insurance business and was not carrying on any other business, surplus or deficit as per shareholders account is to be aggregated with surplus or deficit with policyholders account for the purpose of determining the Profit & Loss Account of an assessee engaged in life insurance business u/s 44 of the Act. - AT
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