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 held that the notional foreign exchange gain arising on conversion of a Euro loan to a foreign subsidiary as at the balance-sheet date is capital and notional, and therefore not taxable income; the Assessing Officer's addition under ICDS VI was deleted and the CIT(A)'s order upheld. Expenditure incurred to obtain USFDA approval for clinical trials, including costs of supplying both bare and drug-eluting stents, was held to be wholly and exclusively for business under s.37(1) and allowed. The AO's reliance on a lesser notice period under s.148A(b) was found inapplicable on the facts; revenue's appeal dismissed.
ITAT held that the notional foreign exchange gain arising on conversion of a Euro loan to a foreign subsidiary as at the balance-sheet date is capital and notional, and therefore not taxable income; the Assessing Officer's addition under ICDS VI was deleted and the CIT(A)'s order upheld. Expenditure incurred to obtain USFDA approval for clinical trials, including costs of supplying both bare and drug-eluting stents, was held to be wholly and exclusively for business under s.37(1) and allowed. The AO's reliance on a lesser notice period under s.148A(b) was found inapplicable on the facts; revenue's appeal dismissed.
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