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...
Addition of commission expenses and franking charges - Allowable business expenditure or not? - The Tribunal acknowledged that the assessee had provided details of the commission agents to whom payments were made, along with invoices. However, it noted that certain details, such as the PAN of some agents, were missing. The Tribunal directed the AO to verify whether these agents had declared the commission income in their tax returns. If the agents could demonstrate that they declared the income, and the services provided were genuine, the commission expenses should be allowed.
Addition of commission expenses and franking charges - Allowable business expenditure or not? - The Tribunal acknowledged that the assessee had provided details of the commission agents to whom payments were made, along with invoices. However, it noted that certain details, such as the PAN of some agents, were missing. The Tribunal directed the AO to verify whether these agents had declared the commission income in their tax returns. If the agents could demonstrate that they declared the income, and the services provided were genuine, the commission expenses should be allowed.
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