Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
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Allowability of Derivative loss - separate addition on account of alleged payment of margin monies on an estimated basis - The Tribunal emphasized that in derivative transactions, the actual transfer of money under the heads 'purchase and sale' is notional, and only the resultant difference paid or received at the end of the transaction is relevant. The Tribunal recognized that losses incurred in derivative transactions, if paid by the assessee through regular banking channels and adequately evidenced, should not lead to additional disallowance on an estimated basis for alleged payment of margin monies. - AT
Allowability of Derivative loss - separate addition on account of alleged payment of margin monies on an estimated basis - The Tribunal emphasized that in derivative transactions, the actual transfer of money under the heads 'purchase and sale' is notional, and only the resultant difference paid or received at the end of the transaction is relevant. The Tribunal recognized that losses incurred in derivative transactions, if paid by the assessee through regular banking channels and adequately evidenced, should not lead to additional disallowance on an estimated basis for alleged payment of margin monies. - AT
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