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...
ITAT allowed the taxpayer's claim for deduction of expenditure incurred in an abandoned project, recognizing that the project abandonment was due to reasons beyond the assessee's control. The tribunal held that the written-off expenses under 'work in progress' were commercially justified and not subject to tax authority scrutiny. The tribunal directed the Assessing Officer to delete the disallowance in both the section 143(1) intimation and section 143(3) assessment order, effectively permitting the expenditure deduction based on the commercial reasonableness of the assessee's decision.
ITAT allowed the taxpayer's claim for deduction of expenditure incurred in an abandoned project, recognizing that the project abandonment was due to reasons beyond the assessee's control. The tribunal held that the written-off expenses under 'work in progress' were commercially justified and not subject to tax authority scrutiny. The tribunal directed the Assessing Officer to delete the disallowance in both the section 143(1) intimation and section 143(3) assessment order, effectively permitting the expenditure deduction based on the commercial reasonableness of the assessee's decision.
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