Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
TNMM aggregation prevented separate benchmarking of IT support services where accepted segmental margins already included the associated-enterprise markup and the services were inextricably linked to the core business. The transfer-pricing adjustment on the IT support-services margin was deleted. Notional interest on overdue associated-enterprise receivables was unwarranted because the taxpayer was debt-free, incurred no significant interest cost, and no new material justified departure from earlier treatment; the related adjustment was deleted. Capital expenditure on an in-house scientific-research facility remained deductible under section 35(1)(iv) despite the concessional tax regime and absence of valid Form 3CM, which was relevant to section 35(2AB), not section 35(1)(iv).
TNMM aggregation prevented separate benchmarking of IT support services where accepted segmental margins already included the associated-enterprise markup and the services were inextricably linked to the core business. The transfer-pricing adjustment on the IT support-services margin was deleted. Notional interest on overdue associated-enterprise receivables was unwarranted because the taxpayer was debt-free, incurred no significant interest cost, and no new material justified departure from earlier treatment; the related adjustment was deleted. Capital expenditure on an in-house scientific-research facility remained deductible under section 35(1)(iv) despite the concessional tax regime and absence of valid Form 3CM, which was relevant to section 35(2AB), not section 35(1)(iv).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4921 
