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...
Imposition of penalty - penalty on signatory - Unless cogent evidence is brought to record to say that retraction in affidavit is untruthful and the appellant was instrumental to create fake documents, role of the appellant cannot be appreciated. - AT
Imposition of penalty - penalty on signatory - Unless cogent evidence is brought to record to say that retraction in affidavit is untruthful and the appellant was instrumental to create fake documents, role of the appellant cannot be appreciated. - AT
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