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...
Validity of reopening of assessment - when reference to DVO itself is invalid, the report received as a result of the reference cannot constitute material for forming the belief that an income or wealth tax escaped assessment - AT
Validity of reopening of assessment - when reference to DVO itself is invalid, the report received as a result of the reference cannot constitute material for forming the belief that an income or wealth tax escaped assessment - AT
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