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...
Assessee fails whether the enhancement in its income is considered as on account of a TP adjustment or for denial of deduction u/s. 10A, i.e., from the standpoint of both Explanation 1 or 7 to s. 271(1)(c) – the levy of penalty upheld - AT
Assessee fails whether the enhancement in its income is considered as on account of a TP adjustment or for denial of deduction u/s. 10A, i.e., from the standpoint of both Explanation 1 or 7 to s. 271(1)(c) – the levy of penalty upheld - AT
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