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...
Executive Assistants are not entitled to inter-Commissionerate transfer where each Cadre Controlling Authority maintains a separate cadre and the applicable Recruitment Rules provide no absorption by transfer into another Commissionerate. The transfer policy therefore applies to this cadre, and appointment in the transferee Commissionerate cannot be secured through inter-Commissionerate transfer. Transfers treated as deemed loan arrangements may consequently result in repatriation. A request for relaxation on medical grounds may be made by representation for consideration on its merits.
Executive Assistants are not entitled to inter-Commissionerate transfer where each Cadre Controlling Authority maintains a separate cadre and the applicable Recruitment Rules provide no absorption by transfer into another Commissionerate. The transfer policy therefore applies to this cadre, and appointment in the transferee Commissionerate cannot be secured through inter-Commissionerate transfer. Transfers treated as deemed loan arrangements may consequently result in repatriation. A request for relaxation on medical grounds may be made by representation for consideration on its merits.
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