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...
Carry forward and set off of business losses u/s 32(2) is subject to the provisions of Sections 72(2) and 72(3). Depreciation allowance carried forward u/s 32(2), though deemed a business loss for Sections 71 and 72, can only be set off against profits or gains from any business or profession, and not against income from other sources. Section 72 is not always subject to Section 71, despite Section 32(2) permitting carry forward of depreciation allowance subject to Section 72. The High Court dismissed the writ petition, finding no error warranting exercise of jurisdiction under Article 226 of the Constitution.
Carry forward and set off of business losses u/s 32(2) is subject to the provisions of Sections 72(2) and 72(3). Depreciation allowance carried forward u/s 32(2), though deemed a business loss for Sections 71 and 72, can only be set off against profits or gains from any business or profession, and not against income from other sources. Section 72 is not always subject to Section 71, despite Section 32(2) permitting carry forward of depreciation allowance subject to Section 72. The High Court dismissed the writ petition, finding no error warranting exercise of jurisdiction under Article 226 of the Constitution.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
