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...
Penalty paid to RBI for breach of regulatory directions was treated as a regulatory levy and not as expenditure for an offence or infraction of law under Explanation 2 to section 37(1), so the deduction was allowed. CSR expenditure was disallowed because the record did not show that it exceeded the statutory CSR obligation, and prior decisions based on the pre-amendment position did not apply after insertion of Explanation 2. The Tribunal also reiterated that appellate authorities can entertain fresh claims not made before the Assessing Officer, so the bad-debt recovery issue was remitted to the Commissioner (Appeals) and the PSLC taxability issue was remitted to the Assessing Officer for fresh adjudication.
Penalty paid to RBI for breach of regulatory directions was treated as a regulatory levy and not as expenditure for an offence or infraction of law under Explanation 2 to section 37(1), so the deduction was allowed. CSR expenditure was disallowed because the record did not show that it exceeded the statutory CSR obligation, and prior decisions based on the pre-amendment position did not apply after insertion of Explanation 2. The Tribunal also reiterated that appellate authorities can entertain fresh claims not made before the Assessing Officer, so the bad-debt recovery issue was remitted to the Commissioner (Appeals) and the PSLC taxability issue was remitted to the Assessing Officer for fresh adjudication.
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