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...
Capital gain on sale of shares – If the purchases and sales are effective within 90 days then they should be treated as trading of shares and if the transactions are held more than 90 days then those purchase and sales should be treated as investment portfolio - AT
Capital gain on sale of shares – If the purchases and sales are effective within 90 days then they should be treated as trading of shares and if the transactions are held more than 90 days then those purchase and sales should be treated as investment portfolio - AT
Note: It is a system-generated summary and is for quick reference only.