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...
Hybrid seed production on leased agricultural land was treated as agricultural income because the assessee had exclusive use and beneficial control of the land, supervised cultivation, bore the cultivation risk, and owned the produce; use of technical methods did not change the agricultural character, so the addition as business income was deleted. Trade creditors for professional and compliance expenses were held outside section 68 because they were not loan credits and were later paid through banking channels, so that addition was deleted. Balance differences in creditor confirmations were not taxable under section 69C or section 41(1) absent proof of remission or cessation of liability, so that addition was also deleted.
Hybrid seed production on leased agricultural land was treated as agricultural income because the assessee had exclusive use and beneficial control of the land, supervised cultivation, bore the cultivation risk, and owned the produce; use of technical methods did not change the agricultural character, so the addition as business income was deleted. Trade creditors for professional and compliance expenses were held outside section 68 because they were not loan credits and were later paid through banking channels, so that addition was deleted. Balance differences in creditor confirmations were not taxable under section 69C or section 41(1) absent proof of remission or cessation of liability, so that addition was also deleted.
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