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 u/s 147 – Reopening made on the basis of DVO’s report - once reference itself is held to be invalid or bad, the DVO’s report obtained consequent thereto cannot be used for reopening of the assessment - AT
Validity of reopening of assessment u/s 147 – Reopening made on the basis of DVO’s report - once reference itself is held to be invalid or bad, the DVO’s report obtained consequent thereto cannot be used for reopening of the assessment - AT
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