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...
The ITAT Delhi ruled on the correct classification of income from property lease - whether as rental income, business income, or other sources. The lease agreement included not only the building but also substantial infrastructure and amenities, indicating a commercial asset lease. The user accepted possession of the entire building with services provided, showing a business intent. Tax authorities erred in reclassifying income as rental, leading to disallowed expenses and depreciation. The appeals were allowed, emphasizing the commercial nature of the arrangement.
The ITAT Delhi ruled on the correct classification of income from property lease - whether as rental income, business income, or other sources. The lease agreement included not only the building but also substantial infrastructure and amenities, indicating a commercial asset lease. The user accepted possession of the entire building with services provided, showing a business intent. Tax authorities erred in reclassifying income as rental, leading to disallowed expenses and depreciation. The appeals were allowed, emphasizing the commercial nature of the arrangement.
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