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...
Denial of refund claim - Refund of excess tax paid - excess payments were reflected as receipts in the general ledger account and there was no corresponding debit entries in the name of any of their customers. Therefore, the incidence of tax was not passed on to any other person. - AT
Denial of refund claim - Refund of excess tax paid - excess payments were reflected as receipts in the general ledger account and there was no corresponding debit entries in the name of any of their customers. Therefore, the incidence of tax was not passed on to any other person. - AT
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