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...
Deemed dividend u/s 2(22)(e) - beneficial owner of 30% - The plea of the assessee that no direct payment was made by the company to the assessee has no relevance as the case of the assessee falls within the third limb i.e. payment on behalf or for the individual benefit of the shareholder.... - AT
Deemed dividend u/s 2(22)(e) - beneficial owner of 30% - The plea of the assessee that no direct payment was made by the company to the assessee has no relevance as the case of the assessee falls within the third limb i.e. payment on behalf or for the individual benefit of the shareholder.... - AT
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