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 held that the alleged excess business loss arose from a clerical computation mismatch between book loss and loss computed under the Act, with no adverse scrutiny finding on the underlying claim, so the disallowance was deleted. It further accepted compensation paid to remove encroachment as a genuine cost of improvement for long-term capital gains computation, noting that the supporting agreements, payment records and verification material showed no serious discrepancy and the lower authorities had rejected the claim only on a general assertion of incomplete details. The indexed cost of improvement was therefore allowed and the appeal succeeded in full.
ITAT held that the alleged excess business loss arose from a clerical computation mismatch between book loss and loss computed under the Act, with no adverse scrutiny finding on the underlying claim, so the disallowance was deleted. It further accepted compensation paid to remove encroachment as a genuine cost of improvement for long-term capital gains computation, noting that the supporting agreements, payment records and verification material showed no serious discrepancy and the lower authorities had rejected the claim only on a general assertion of incomplete details. The indexed cost of improvement was therefore allowed and the appeal succeeded in full.
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