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...
Section 2(1-A) amended retrospectively to restrict agricultural land exemption to rural areas, introducing concept of "urban agricultural land" under "capital asset" definition. Tribunal refused to admit additional grounds on merits of Section 115JB MAT computation. Once agricultural land income exempt, cannot be added to book profits for MAT. Tribunal should have allowed submissions before dismissing grounds. HC allowed appeal, set aside Tribunal order, answered legal question in appellant's favor.
Section 2(1-A) amended retrospectively to restrict agricultural land exemption to rural areas, introducing concept of "urban agricultural land" under "capital asset" definition. Tribunal refused to admit additional grounds on merits of Section 115JB MAT computation. Once agricultural land income exempt, cannot be added to book profits for MAT. Tribunal should have allowed submissions before dismissing grounds. HC allowed appeal, set aside Tribunal order, answered legal question in appellant's favor.
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