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...
Levy of penalty u/s 271D/E – Violation of provisions of section 269SS - 'journal entries' are outside the scope of the relevant penal provisions - completing the “empty formalities“ of payments and repayments by issuing/receiving cheque to swap/squire up the transactions, is not the intention of the provisions of section 269SS - AT
Levy of penalty u/s 271D/E – Violation of provisions of section 269SS - 'journal entries' are outside the scope of the relevant penal provisions - completing the “empty formalities“ of payments and repayments by issuing/receiving cheque to swap/squire up the transactions, is not the intention of the provisions of section 269SS - AT
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