Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Deduction u/s 80IA(4) on wind mills and solar power plants - Whether each windmill and solar power plant installed by the assessee should be considered as separate undertakings or one undertaking? - The Tribunal, referencing its own previous decisions and the lack of any new material facts or judicial precedents, upheld the Commissioner of Income Tax (Appeals)'s ruling. It was concluded that each windmill and solar power plant must be treated as separate undertakings for the calculation of deductions under section 80IA(4), thereby dismissing the Revenue's appeal on this ground. - Furthermore, on Applicability of Notional Brought Forward Losses and Depreciation, the Tribunal followed the principles laid down by the High Courts, which stated that losses from eligible businesses, once set off against other income, cannot be notionally carried forward to reduce the profits of the eligible business in subsequent years for the purpose of computing deduction under section 80IA.
Deduction u/s 80IA(4) on wind mills and solar power plants - Whether each windmill and solar power plant installed by the assessee should be considered as separate undertakings or one undertaking? - The Tribunal, referencing its own previous decisions and the lack of any new material facts or judicial precedents, upheld the Commissioner of Income Tax (Appeals)'s ruling. It was concluded that each windmill and solar power plant must be treated as separate undertakings for the calculation of deductions under section 80IA(4), thereby dismissing the Revenue's appeal on this ground. - Furthermore, on Applicability of Notional Brought Forward Losses and Depreciation, the Tribunal followed the principles laid down by the High Courts, which stated that losses from eligible businesses, once set off against other income, cannot be notionally carried forward to reduce the profits of the eligible business in subsequent years for the purpose of computing deduction under section 80IA.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
