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 of capital gains - denial of adjustments to full value of sale consideration towards amount lying in Escrow account while determining the LTCG - ITAT accepted the revised computation of capital gains, excluding the amount retained in the escrow account, which was neither received nor expected to be received by the assessee due to subsequent events indicating significant liabilities against the escrow. - As conceded on behalf of the assessee, the amount recovered out of escrow account by the assessee in the later years shall be liable to taxation in the respective years of receipt or accrual.
Taxability of capital gains - denial of adjustments to full value of sale consideration towards amount lying in Escrow account while determining the LTCG - ITAT accepted the revised computation of capital gains, excluding the amount retained in the escrow account, which was neither received nor expected to be received by the assessee due to subsequent events indicating significant liabilities against the escrow. - As conceded on behalf of the assessee, the amount recovered out of escrow account by the assessee in the later years shall be liable to taxation in the respective years of receipt or accrual.
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