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...
Consultancy charges – The substance of the agreement is for consulting the foreign party for marketing the product of the assessee in South East Asian countries. Therefore, it is only consultancy charges - TDS to be deducted on payment – AT
Consultancy charges – The substance of the agreement is for consulting the foreign party for marketing the product of the assessee in South East Asian countries. Therefore, it is only consultancy charges - TDS to be deducted on payment – AT
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