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...
Validity of reopening of assessment – the foundation of the reopening itself being erroneous insofar as the reasons recorded are erroneous and are not supported by any evidence but are contrary to the evidence as are available on record - AT
Validity of reopening of assessment – the foundation of the reopening itself being erroneous insofar as the reasons recorded are erroneous and are not supported by any evidence but are contrary to the evidence as are available on record - AT
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