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...
Calculation under export obligation - the export proceeds realized in any currency would be converted into USD and the term ‘any currency’ would refer to the foreign currency realized through exports, since the aim of the scheme was to promote foreign exchange earnings in fully convertible currency. Subsequent de-valuation of the rupee cannot come to the aid of the appellant - HC
Calculation under export obligation - the export proceeds realized in any currency would be converted into USD and the term ‘any currency’ would refer to the foreign currency realized through exports, since the aim of the scheme was to promote foreign exchange earnings in fully convertible currency. Subsequent de-valuation of the rupee cannot come to the aid of the appellant - HC
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