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...
Permanent Establishment – Chargeability of payments received u/s 9(1)(vii) r.w section 115A and 44DA of the Act - The taxpayer had a fixed place PE in India because RRIL’s premises were ‘available’ to all of employees and assessee paid all the expenses in maintaining its premises - AAR
Permanent Establishment – Chargeability of payments received u/s 9(1)(vii) r.w section 115A and 44DA of the Act - The taxpayer had a fixed place PE in India because RRIL’s premises were ‘available’ to all of employees and assessee paid all the expenses in maintaining its premises - AAR
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