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...
Royalty payments treated as revenue expenditure, deductible in full; capital expenditure treatment rejected. Bad debt deduction allowed u/s 28, following Supreme Court precedent in Shriram Chits case; Revenue appeal rejected. Division Bench judgment of same Court cited, clarifying expenditure to acquire intangible asset not automatically capital expenditure; enduring nature of benefit key consideration. Appellate orders deleting disallowances upheld by High Court.
Royalty payments treated as revenue expenditure, deductible in full; capital expenditure treatment rejected. Bad debt deduction allowed u/s 28, following Supreme Court precedent in Shriram Chits case; Revenue appeal rejected. Division Bench judgment of same Court cited, clarifying expenditure to acquire intangible asset not automatically capital expenditure; enduring nature of benefit key consideration. Appellate orders deleting disallowances upheld by High Court.
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