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...
Determination of arm's length price (ALP) - rate of commission charged by the assessee from its AEs - It is the assessee who has to substantiate that the price charged is at ALP and not vice versa. The assessee has to face the music if it fails to prove so. - AT
Determination of arm's length price (ALP) - rate of commission charged by the assessee from its AEs - It is the assessee who has to substantiate that the price charged is at ALP and not vice versa. The assessee has to face the music if it fails to prove so. - AT
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