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...
Income on account of interest treated as income from other sources – Disallowance of remuneration to partners from interest income - deduction allowed considering as business income - AT
Income on account of interest treated as income from other sources – Disallowance of remuneration to partners from interest income - deduction allowed considering as business income - AT
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