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...
Retrospectively amended Section 115JA was applied to treat amounts set aside for bad and doubtful debts as a provision for diminution in the value of an asset, so the addition in book profit computation was upheld and the assessee's challenge failed. By contrast, the audit report requirement for a deduction claim under Section 80IA(7) was treated as directory for the relevant period, so failure to file it before assessment did not defeat the claim when the report was produced before the appellate authority. The appeal was therefore partly allowed, with the Revenue succeeding on book profit treatment and the assessee succeeding on the audit-report issue.
Retrospectively amended Section 115JA was applied to treat amounts set aside for bad and doubtful debts as a provision for diminution in the value of an asset, so the addition in book profit computation was upheld and the assessee's challenge failed. By contrast, the audit report requirement for a deduction claim under Section 80IA(7) was treated as directory for the relevant period, so failure to file it before assessment did not defeat the claim when the report was produced before the appellate authority. The appeal was therefore partly allowed, with the Revenue succeeding on book profit treatment and the assessee succeeding on the audit-report issue.
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