Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
Alternative statutory remedy under GST bars writ challenge where classification, notice variance, and hearing disputes require factual appellate revie...
The Delhi High Court addressed issues related to reimbursement of software costs, reimbursement of expatriate salaries, and lease registration charges. The court held that the addition made for reimbursement of software costs was not proven as the assessee failed to demonstrate actual receipt and use of software in India for business purposes. Referring to a Supreme Court judgment, it was established that payments to nonresident software suppliers were not royalty and not subject to TDS. The court found the ITAT's deletion of the addition for expatriate salaries lacked sufficient reasoning and required further consideration. Regarding lease registration charges, the ITAT's decision to not amortize them over the lease period was upheld, as registration charges are one-time expenses not linked to the lease duration. The court admitted appeals to determine if the ITAT erred in deleting the additions without considering the potential double deduction nature of the claims.
The Delhi High Court addressed issues related to reimbursement of software costs, reimbursement of expatriate salaries, and lease registration charges. The court held that the addition made for reimbursement of software costs was not proven as the assessee failed to demonstrate actual receipt and use of software in India for business purposes. Referring to a Supreme Court judgment, it was established that payments to nonresident software suppliers were not royalty and not subject to TDS. The court found the ITAT's deletion of the addition for expatriate salaries lacked sufficient reasoning and required further consideration. Regarding lease registration charges, the ITAT's decision to not amortize them over the lease period was upheld, as registration charges are one-time expenses not linked to the lease duration. The court admitted appeals to determine if the ITAT erred in deleting the additions without considering the potential double deduction nature of the claims.
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TaxTMI 
TaxTMI 
of 4888 
