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...
Manpower Supply Service – employees on deputation - one of the features of manpower supply service was that the salary of the persons supplied was paid by the manpower supply agency in full and payment by the service receiver was made to the supplier of the service and not to the employee - stay granted - AT
Manpower Supply Service – employees on deputation - one of the features of manpower supply service was that the salary of the persons supplied was paid by the manpower supply agency in full and payment by the service receiver was made to the supplier of the service and not to the employee - stay granted - AT
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