Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
The ITAT held that identical issues arose in the assessee's own case for AY 2019-20 which was decided in favour of the assessee, thus there is no justification in attributing the profit on offshore sale of equipment. Regarding receipt from Glidepath, New Zealand, the ITAT found no artificial splitting of contracts and relied on the Supreme Court's decision in Morgan Stanley to hold that the receipt cannot be subjected to tax. For receipts from KITCOL, TTD and CIAL, the matter was restored to the AO to examine double taxation after the assessee furnishes evidence of offering the receipts in earlier years.
The ITAT held that identical issues arose in the assessee's own case for AY 2019-20 which was decided in favour of the assessee, thus there is no justification in attributing the profit on offshore sale of equipment. Regarding receipt from Glidepath, New Zealand, the ITAT found no artificial splitting of contracts and relied on the Supreme Court's decision in Morgan Stanley to hold that the receipt cannot be subjected to tax. For receipts from KITCOL, TTD and CIAL, the matter was restored to the AO to examine double taxation after the assessee furnishes evidence of offering the receipts in earlier years.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
