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...
Disallowance of deduction u/s 80IA(4)(i) - The tribunal noted the distinction between a developer (who assumes significant risks and responsibilities for the project) and a contractor (who does not assume such risks and is only responsible for executing work as per the contract) - The tribunal directed that, based on the nature of contracts and risks assumed, the assessee's claim for deductions under Section 80IA(4) should be allowed, emphasizing the role of the assessee as a developer rather than a mere contractor.
Disallowance of deduction u/s 80IA(4)(i) - The tribunal noted the distinction between a developer (who assumes significant risks and responsibilities for the project) and a contractor (who does not assume such risks and is only responsible for executing work as per the contract) - The tribunal directed that, based on the nature of contracts and risks assumed, the assessee's claim for deductions under Section 80IA(4) should be allowed, emphasizing the role of the assessee as a developer rather than a mere contractor.
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