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...
Taxability in the hands of partners v/s firm - transfer of capital asset by firm to partners - There is no merit in the arguments advanced by assessee, that transfer of flats to partners by way of MOU does not give rise to any income in the hands of the firm, because as per provisions of section 45(4), transfer of capital asset by firm to partners is a transfer which need to be dealt in accordance with law. - The income is taxable in the hands of firm - However, the same is exemption u/s 80IB(10) - AT
Taxability in the hands of partners v/s firm - transfer of capital asset by firm to partners - There is no merit in the arguments advanced by assessee, that transfer of flats to partners by way of MOU does not give rise to any income in the hands of the firm, because as per provisions of section 45(4), transfer of capital asset by firm to partners is a transfer which need to be dealt in accordance with law. - The income is taxable in the hands of firm - However, the same is exemption u/s 80IB(10) - AT
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