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 allowed the assessee's appeal in part, holding that payments made to the builder for civil, plumbing and electrical works constituted part of cost of acquisition and permitting Rs.11,35,023 as cost of acquisition, noting receipts and payment statements and absence of bank records due to account closure. Concurrently ITAT sustained exclusion of certain improvement claims, directing the AO to disallow Rs.5,49,644 as personal effects or non-deductible items, while accepting that embedded permanent fixtures qualify as part of capital improvement. Claims for air travel, boarding, meals, local transport and related expenses were disallowed as not incurred "wholly and exclusively" in connection with the transfer.
ITAT allowed the assessee's appeal in part, holding that payments made to the builder for civil, plumbing and electrical works constituted part of cost of acquisition and permitting Rs.11,35,023 as cost of acquisition, noting receipts and payment statements and absence of bank records due to account closure. Concurrently ITAT sustained exclusion of certain improvement claims, directing the AO to disallow Rs.5,49,644 as personal effects or non-deductible items, while accepting that embedded permanent fixtures qualify as part of capital improvement. Claims for air travel, boarding, meals, local transport and related expenses were disallowed as not incurred "wholly and exclusively" in connection with the transfer.
Note: It is a system-generated summary and is for quick reference only.