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 rejected the Revenue's Rule 46A objection because the EPCG licence documents and computation were already part of the record before the Assessing Officer, and no fresh evidence had been admitted by the first appellate authority. It further upheld deletion of the addition relating to the Government grant, holding that the amount had been credited in the books under Ind-AS-compliant accounting, was tax neutral for income-tax purposes, and had already been included in the returned total income. A further addition would therefore result in double addition. The Revenue's appeal was dismissed.
ITAT rejected the Revenue's Rule 46A objection because the EPCG licence documents and computation were already part of the record before the Assessing Officer, and no fresh evidence had been admitted by the first appellate authority. It further upheld deletion of the addition relating to the Government grant, holding that the amount had been credited in the books under Ind-AS-compliant accounting, was tax neutral for income-tax purposes, and had already been included in the returned total income. A further addition would therefore result in double addition. The Revenue's appeal was dismissed.
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