Scope of intermediary status for data hosting services: tribunal finds provider not intermediary, services exported and not taxable, limited remand on...
CENVAT credit availability after omission of Rule 12B in textiles confirmed; late addendum to SCN introducing new grounds held time-barred and invalid...
Export of Wheat Flour and related products subject to online allocation, eligibility criteria, non-transferable six-month authorisations and reporting...
Straight-line lease rental accounting change results in penalty quashed where disclosed accounts and bona fide arguable accounting interpretation exis...
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Aftermarket trading expenses for purposes of computing deduction under s. 80IC were held allocable on the basis of aftermarket trading sales ratio, as the expenses were incurred to earn such sales; the contrary allocation on total sales was rejected and the Revenue's challenge failed while the assessee succeeded. Adjustment of eligible profits under s. 80IC by recomputing arm's length price for stock transfers to head office was disallowed because s. 80IA(12) was inapplicable where the eligible unit continued with the same assessee post-amalgamation; relief was granted to the assessee. Reimbursement payments to non-residents were held not constituting income, so no withholding under s. 195 arose and disallowance under s. 40(a)(i) was deleted. Royalty was treated as revenue expenditure, and a notional 10% markup to head office was disallowed. - ITAT
Aftermarket trading expenses for purposes of computing deduction under s. 80IC were held allocable on the basis of aftermarket trading sales ratio, as the expenses were incurred to earn such sales; the contrary allocation on total sales was rejected and the Revenue's challenge failed while the assessee succeeded. Adjustment of eligible profits under s. 80IC by recomputing arm's length price for stock transfers to head office was disallowed because s. 80IA(12) was inapplicable where the eligible unit continued with the same assessee post-amalgamation; relief was granted to the assessee. Reimbursement payments to non-residents were held not constituting income, so no withholding under s. 195 arose and disallowance under s. 40(a)(i) was deleted. Royalty was treated as revenue expenditure, and a notional 10% markup to head office was disallowed. - ITAT
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