Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
ITAT affirmed that the assessee is entitled to deductions under both s.36(1)(vii) and s.36(1)(viia)(c), holding the proviso to s.36(1)(vii) merely caps bad-debt write-offs by the credit balance in provisions to prevent double deduction; factual review showed no excess or duplication, so CIT(A)'s allowance was upheld. On s.14A, the Tribunal directed the AO to confine disallowance to the assessee's suo-motu pro-rata allocation to investment-department costs, rejecting the AO's challenge absent specific contrary accounting findings. Deductions under s.36(1)(viii) were held independent of s.36(1)(viia)(c) computations. The amortised rent issue was remitted to the AO for reconsideration under s.158A upon Form-8 compliance.
ITAT affirmed that the assessee is entitled to deductions under both s.36(1)(vii) and s.36(1)(viia)(c), holding the proviso to s.36(1)(vii) merely caps bad-debt write-offs by the credit balance in provisions to prevent double deduction; factual review showed no excess or duplication, so CIT(A)'s allowance was upheld. On s.14A, the Tribunal directed the AO to confine disallowance to the assessee's suo-motu pro-rata allocation to investment-department costs, rejecting the AO's challenge absent specific contrary accounting findings. Deductions under s.36(1)(viii) were held independent of s.36(1)(viia)(c) computations. The amortised rent issue was remitted to the AO for reconsideration under s.158A upon Form-8 compliance.
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