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...
Unabsorbed depreciation carried forward under Section 32(2) retains the character of current-year loss and may be set off against business income or other income, except capital gains; on that basis, the assessee was entitled to set off the depreciation against the addition made for unaccounted stock. The revenue's reliance on Section 79A failed because it was inserted later and applied only from 01.04.2022, and Section 115BBE(2) was also inapplicable because the assessment was not framed under that provision. The substantial questions of law were answered in favour of the assessee.
Unabsorbed depreciation carried forward under Section 32(2) retains the character of current-year loss and may be set off against business income or other income, except capital gains; on that basis, the assessee was entitled to set off the depreciation against the addition made for unaccounted stock. The revenue's reliance on Section 79A failed because it was inserted later and applied only from 01.04.2022, and Section 115BBE(2) was also inapplicable because the assessment was not framed under that provision. The substantial questions of law were answered in favour of the assessee.
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