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...
Forward contract a ‘hedging transaction’ or a ‘Forward transaction’ - So long as the total FCs does not exceed the exports of the year plus outstanding export receivable, the FCs can constitute 'hedging transaction' - AT
Forward contract a ‘hedging transaction’ or a ‘Forward transaction’ - So long as the total FCs does not exceed the exports of the year plus outstanding export receivable, the FCs can constitute 'hedging transaction' - AT
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