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...
The High Court remanded the proceedings to the Assessing Officer to consider the assessee's alternate claim for loss arising out of Held till Maturity securities under the head 'income from business and profession'. The Income Tax Appellate Tribunal's finding that no material was supplied by the assessee to substantiate the claim was held unsustainable. The assessee accepted the Income Tax Appellate Tribunal's decision treating profits from the sale of Held till Maturity securities as capital gains.
The High Court remanded the proceedings to the Assessing Officer to consider the assessee's alternate claim for loss arising out of Held till Maturity securities under the head 'income from business and profession'. The Income Tax Appellate Tribunal's finding that no material was supplied by the assessee to substantiate the claim was held unsustainable. The assessee accepted the Income Tax Appellate Tribunal's decision treating profits from the sale of Held till Maturity securities as capital gains.
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