Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
The ITAT, an Appellate Tribunal, addressed two main issues. Firstly, regarding the computation of book profit u/s 115JB, discrepancies arose from the deduction claimed by the assessee for brought forward losses or unabsorbed depreciation. The Tribunal directed a fresh verification by the Assessing Officer based on the provided chart. Secondly, concerning TDS u/s 195 for payments to non-residents, the Tribunal held that payments to certain countries were not taxable in India under treaty provisions, thus no tax deduction was required. Additionally, the Tribunal ruled in favor of the assessee regarding disallowance of advances written off, as supported by the Commissioner (Appeals)'s factual findings.
The ITAT, an Appellate Tribunal, addressed two main issues. Firstly, regarding the computation of book profit u/s 115JB, discrepancies arose from the deduction claimed by the assessee for brought forward losses or unabsorbed depreciation. The Tribunal directed a fresh verification by the Assessing Officer based on the provided chart. Secondly, concerning TDS u/s 195 for payments to non-residents, the Tribunal held that payments to certain countries were not taxable in India under treaty provisions, thus no tax deduction was required. Additionally, the Tribunal ruled in favor of the assessee regarding disallowance of advances written off, as supported by the Commissioner (Appeals)'s factual findings.
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