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...
Neither the freight nor the inspection charges are paid by the appellant company for any services rendered by these company in India, and nor the payments are made to these parties in India, and therefore, by no imagination either the provisions of section 194C or section 195 are applicable - AT
Neither the freight nor the inspection charges are paid by the appellant company for any services rendered by these company in India, and nor the payments are made to these parties in India, and therefore, by no imagination either the provisions of section 194C or section 195 are applicable - AT
Note: It is a system-generated summary and is for quick reference only.