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...
Calculation of Capital Gain - Non-Resident - Applicability of section 144C - eligible assessee - The appellant contested the rejection of their valuation report and the adoption of circle rates, arguing that the valuation report should have been relied upon. Discrepancies in the calculation of capital gains, particularly concerning brokerage expenses and stamp duty, were also highlighted. The Tribunal found merit in several of the appellant's arguments, directing the AO to reconsider certain aspects and providing relief to the appellant.
Calculation of Capital Gain - Non-Resident - Applicability of section 144C - eligible assessee - The appellant contested the rejection of their valuation report and the adoption of circle rates, arguing that the valuation report should have been relied upon. Discrepancies in the calculation of capital gains, particularly concerning brokerage expenses and stamp duty, were also highlighted. The Tribunal found merit in several of the appellant's arguments, directing the AO to reconsider certain aspects and providing relief to the appellant.
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