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...
Rectification u/s 154 - Characterization of receipts - Exemption of interest on enhanced compensation from tax denied u/s. 10(37) - However, the Appellate Tribunal dismissed the appeal, affirming the Assessing Officer's decision to tax 50% of the interest. The Tribunal held that the interest did not fall under section 28 of the LAA and was taxable as income. The plea for rectification under section 154 was rejected as there was no mistake in the assessment order.
Rectification u/s 154 - Characterization of receipts - Exemption of interest on enhanced compensation from tax denied u/s. 10(37) - However, the Appellate Tribunal dismissed the appeal, affirming the Assessing Officer's decision to tax 50% of the interest. The Tribunal held that the interest did not fall under section 28 of the LAA and was taxable as income. The plea for rectification under section 154 was rejected as there was no mistake in the assessment order.
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