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...
Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude certain companies. Transfer pricing adjustment for interest on receivables - TPO's calculation of interest on entire closing balance incorrect. TPO instructed to compute interest based on delay for each invoice beyond grace period after examining agreements or market practice. Employee's PF contribution disallowed for non-compliance with statutory deposit timelines. No long-term capital gain on amount credited to capital reserve pursuant to merger, covered u/s 47(vi). Double addition in computation corrected. Finance cost disallowance deleted as no transfer pricing adjustment proposed. Advance tax credit and TDS credit from merged entity directed to be allowed based on evidence.
Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude certain companies. Transfer pricing adjustment for interest on receivables - TPO's calculation of interest on entire closing balance incorrect. TPO instructed to compute interest based on delay for each invoice beyond grace period after examining agreements or market practice. Employee's PF contribution disallowed for non-compliance with statutory deposit timelines. No long-term capital gain on amount credited to capital reserve pursuant to merger, covered u/s 47(vi). Double addition in computation corrected. Finance cost disallowance deleted as no transfer pricing adjustment proposed. Advance tax credit and TDS credit from merged entity directed to be allowed based on evidence.
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