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...
Transfer pricing adjustments - Selection of comparable - ITES services cannot be further bifurcated or classified as BPO and KPO services for the purpose of comparability analysis. - AT
Transfer pricing adjustments - Selection of comparable - ITES services cannot be further bifurcated or classified as BPO and KPO services for the purpose of comparability analysis. - AT
Note: It is a system-generated summary and is for quick reference only.