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 adjustment - Offshore activities – The fabrication and supplies are made by the third parties outside India to the assessee and the revenue is not taxing the profits of these third parties - matter remanded back for verification of facts - AT
Transfer pricing adjustment - Offshore activities – The fabrication and supplies are made by the third parties outside India to the assessee and the revenue is not taxing the profits of these third parties - matter remanded back for verification of facts - AT
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