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...
HC dismissed the revenue appeal, rejecting the disallowance of depreciation on securities and pension fund contributions. The court found no merit in the revenue's contention under Section 14A and Rule 8D, particularly noting that the shares were held as stock in trade, rendering the provisions inapplicable. The decision aligned with prior judicial precedent from the coordinate bench, effectively upholding the assessee's position on depreciation and pension fund contributions.
HC dismissed the revenue appeal, rejecting the disallowance of depreciation on securities and pension fund contributions. The court found no merit in the revenue's contention under Section 14A and Rule 8D, particularly noting that the shares were held as stock in trade, rendering the provisions inapplicable. The decision aligned with prior judicial precedent from the coordinate bench, effectively upholding the assessee's position on depreciation and pension fund contributions.
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