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...
Revenue receipt or capital receipt - Foreign exchange gain written back on cancellation of vessel construction contract taxed u/s. 28(iv) - The ITAT agreed with the assessee, holding that the gain was a capital receipt not taxable under Section 28(iv) of the Act. This decision underscores the differentiation between capital and revenue receipts, particularly in the context of foreign exchange gains related to capital assets.
Revenue receipt or capital receipt - Foreign exchange gain written back on cancellation of vessel construction contract taxed u/s. 28(iv) - The ITAT agreed with the assessee, holding that the gain was a capital receipt not taxable under Section 28(iv) of the Act. This decision underscores the differentiation between capital and revenue receipts, particularly in the context of foreign exchange gains related to capital assets.
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