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 in respect of which the impugned payments were made was purely on account of services and there is no transfer of right to use the goods - No TDS u/s 195 as as the same is not royalty - AT
Transactions in respect of which the impugned payments were made was purely on account of services and there is no transfer of right to use the goods - No TDS u/s 195 as as the same is not royalty - AT
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