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...
SEZ-unit profit deduction extends to a voluntary...
SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are examined.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
SEZ-unit profit deduction extends to a voluntary transfer-pricing adjustment disclosed in the return; a pending special leave petition does not displace prevailing Tribunal and jurisdictional High Court authority without a contrary Supreme Court ruling. Ad hoc expenditure disallowance linked to exempt mutual-fund dividend income is addressed through prior assessee-specific rulings. Year-end foreign-exchange loss recognised at the balance-sheet date is treated as allowable business expenditure. In ITeS benchmarking, service providers may be excluded for functional dissimilarity, unavailable segmental information, or failure of the employee-cost filter; medical transcription, billing and coding activities are functionally distinct from the tested ITeS services.
SEZ-unit profit deduction extends to a voluntary transfer-pricing adjustment disclosed in the return; a pending special leave petition does not displace prevailing Tribunal and jurisdictional High Court authority without a contrary Supreme Court ruling. Ad hoc expenditure disallowance linked to exempt mutual-fund dividend income is addressed through prior assessee-specific rulings. Year-end foreign-exchange loss recognised at the balance-sheet date is treated as allowable business expenditure. In ITeS benchmarking, service providers may be excluded for functional dissimilarity, unavailable segmental information, or failure of the employee-cost filter; medical transcription, billing and coding activities are functionally distinct from the tested ITeS services.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
