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...
Transactions between the assessee and its Indian dependent agent permanent establishments having been accepted at arm's length after transfer pricing proceedings, no further profit attribution to the PE was permissible under the treaty principle applied by the Tribunal, and the related addition was deleted. On the refund interest claim, the Tribunal did not decide the entitlement on merits and instead directed factual verification by the Assessing Officer in accordance with law, with disposal based on that verification.
Transactions between the assessee and its Indian dependent agent permanent establishments having been accepted at arm's length after transfer pricing proceedings, no further profit attribution to the PE was permissible under the treaty principle applied by the Tribunal, and the related addition was deleted. On the refund interest claim, the Tribunal did not decide the entitlement on merits and instead directed factual verification by the Assessing Officer in accordance with law, with disposal based on that verification.
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