Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Foreign exchange loss on FCCBs was treated as revenue in nature because the borrowing was for business purposes and not shown to relate to acquisition of capital assets; the disallowance of amortised forex loss was deleted. The corresponding increase in book profit under section 115JB also failed once the underlying addition was removed. Delayed employees' contribution to PF and ESI remained disallowable under section 36(1)(va) despite payment before the section 139(1) due date. In reassessment, the Tribunal held that a fresh addition for the same forex loss amounted to double taxation and deleted it.
Foreign exchange loss on FCCBs was treated as revenue in nature because the borrowing was for business purposes and not shown to relate to acquisition of capital assets; the disallowance of amortised forex loss was deleted. The corresponding increase in book profit under section 115JB also failed once the underlying addition was removed. Delayed employees' contribution to PF and ESI remained disallowable under section 36(1)(va) despite payment before the section 139(1) due date. In reassessment, the Tribunal held that a fresh addition for the same forex loss amounted to double taxation and deleted it.
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