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 adjudicated multiple taxation issues involving property-related income and interest deductions. The tribunal held that: (1) reassessment notice issued to a non-existing entity was null and void, quashing the re-assessment order; (2) pre-construction interest deduction under Section 24(b) was allowable for the entire Rs. 30 Crore loan utilized for property acquisition, rejecting proportionate disallowance; (3) maintenance charges from lessees were correctly classified as business income; and (4) loan substitution for property acquisition was acceptable, permitting interest deduction when nexus between loan and property was established. The tribunal ultimately confirmed the lower appellate authority's order in favor of the assessee.
ITAT adjudicated multiple taxation issues involving property-related income and interest deductions. The tribunal held that: (1) reassessment notice issued to a non-existing entity was null and void, quashing the re-assessment order; (2) pre-construction interest deduction under Section 24(b) was allowable for the entire Rs. 30 Crore loan utilized for property acquisition, rejecting proportionate disallowance; (3) maintenance charges from lessees were correctly classified as business income; and (4) loan substitution for property acquisition was acceptable, permitting interest deduction when nexus between loan and property was established. The tribunal ultimately confirmed the lower appellate authority's order in favor of the assessee.
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