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...
TDS - Distribution of software product - payment made by the assessee to nonresident companies would amount to royalty within the meaning of Article 12 of the DTAA - TDS liable to be deducted - AT
TDS - Distribution of software product - payment made by the assessee to nonresident companies would amount to royalty within the meaning of Article 12 of the DTAA - TDS liable to be deducted - AT
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