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...
Approved gratuity fund contributions adjusted against earlier excess payments were held not to be unpaid provisions, and the gratuity claim was allowable because the fund was approved. Lease-rental disallowance for non-deduction of tax was sustained for the year under appeal, with corresponding deduction allowed in the subsequent year in line with section 40(a)(ia). Short deduction of tax was also treated as falling within section 40(a)(ia), subject to proportionate restriction. Ind AS transition amount was held to be a statutory MAT adjustment, not prior period expense, and the related addition was deleted. Repairs and maintenance expenditure remained revenue in nature despite book capitalisation, and CSR expenditure could not be added back to book profit absent a specific adjustment under section 115JB.
Approved gratuity fund contributions adjusted against earlier excess payments were held not to be unpaid provisions, and the gratuity claim was allowable because the fund was approved. Lease-rental disallowance for non-deduction of tax was sustained for the year under appeal, with corresponding deduction allowed in the subsequent year in line with section 40(a)(ia). Short deduction of tax was also treated as falling within section 40(a)(ia), subject to proportionate restriction. Ind AS transition amount was held to be a statutory MAT adjustment, not prior period expense, and the related addition was deleted. Repairs and maintenance expenditure remained revenue in nature despite book capitalisation, and CSR expenditure could not be added back to book profit absent a specific adjustment under section 115JB.
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