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...
Section 115BAA concessional taxation remains available in subsequent assessment years once a domestic company validly exercises the option through Form 10-IC. The option applies thereafter and cannot be withdrawn, so a fresh Form 10-IC is not required for each succeeding year. Denial of the concessional rate solely because no new form was filed for the relevant subsequent year is unsustainable.
Section 115BAA concessional taxation remains available in subsequent assessment years once a domestic company validly exercises the option through Form 10-IC. The option applies thereafter and cannot be withdrawn, so a fresh Form 10-IC is not required for each succeeding year. Denial of the concessional rate solely because no new form was filed for the relevant subsequent year is unsustainable.
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