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 ITAT held that under section 70(2), short-term capital loss paid with STT can be set off against short-term capital gains not subject to STT, without further classification. Referencing prior judicial precedents, the tribunal found the Assessing Officer erroneously added short-term capital gains already computed by the assessee. The tribunal directed the AO to correctly calculate the assessee's income and levy tax accordingly, allowing the assessee's appeal grounds 1-4 and confirming the setoff of capital losses across different STT scenarios.
The ITAT held that under section 70(2), short-term capital loss paid with STT can be set off against short-term capital gains not subject to STT, without further classification. Referencing prior judicial precedents, the tribunal found the Assessing Officer erroneously added short-term capital gains already computed by the assessee. The tribunal directed the AO to correctly calculate the assessee's income and levy tax accordingly, allowing the assessee's appeal grounds 1-4 and confirming the setoff of capital losses across different STT scenarios.
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