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...
Correct head of income - compensation received for vacating the flat - While the assessee argued for capital gain treatment, the Revenue contended it should be classified as income from other sources. However, the ITAT ruled that the compensation constituted a capital receipt in the hands of the assessee, as it was received from the company out of its own income. The ITAT concluded that the amount was neither capital gain nor income from other sources but rather an application of income by the company. Therefore, the addition made by the assessing officer was deleted, and the appeal of the assessee was allowed.
Correct head of income - compensation received for vacating the flat - While the assessee argued for capital gain treatment, the Revenue contended it should be classified as income from other sources. However, the ITAT ruled that the compensation constituted a capital receipt in the hands of the assessee, as it was received from the company out of its own income. The ITAT concluded that the amount was neither capital gain nor income from other sources but rather an application of income by the company. Therefore, the addition made by the assessing officer was deleted, and the appeal of the assessee was allowed.
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