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...
The ITAT sustained disallowance of proportionate interest on interest-free advances to sister concerns because the assessee failed to show a direct nexus between borrowed funds and business purpose. It accepted that interest relating to assets not put to use must be capitalised, but remanded that issue to the Assessing Officer for factual verification of the assessee's suo motu disallowance. It also upheld disallowance under section 40(a)(ia), holding that the provision applies to both amounts paid and amounts payable during the year without tax deduction at source. The additional ground on conversion charges, including related interest, was rejected as inadmissible and lacking merit.
The ITAT sustained disallowance of proportionate interest on interest-free advances to sister concerns because the assessee failed to show a direct nexus between borrowed funds and business purpose. It accepted that interest relating to assets not put to use must be capitalised, but remanded that issue to the Assessing Officer for factual verification of the assessee's suo motu disallowance. It also upheld disallowance under section 40(a)(ia), holding that the provision applies to both amounts paid and amounts payable during the year without tax deduction at source. The additional ground on conversion charges, including related interest, was rejected as inadmissible and lacking merit.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
