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...
Medical reimbursement up to Rs. 15,000 per employee per annum was held not liable to Fringe Benefit Tax in the employer's hands because a tax charge must rest on clear charging language and cannot be imposed by implication. The Court followed the Karnataka High Court's view that the amount exempt in the employee's hands under the relevant income-tax provision is not subject to FBT, while any reimbursement above that limit may attract tax. The assessment orders levying FBT on reimbursements up to the threshold were set aside.
Medical reimbursement up to Rs. 15,000 per employee per annum was held not liable to Fringe Benefit Tax in the employer's hands because a tax charge must rest on clear charging language and cannot be imposed by implication. The Court followed the Karnataka High Court's view that the amount exempt in the employee's hands under the relevant income-tax provision is not subject to FBT, while any reimbursement above that limit may attract tax. The assessment orders levying FBT on reimbursements up to the threshold were set aside.
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