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...
Reopening of assessment - expenses under the head "management fees" undisclosed - Assessee had disclosed what was relevant and necessary for the purpose of making assessment - this is a clear case of change of opinion - HC
Reopening of assessment - expenses under the head "management fees" undisclosed - Assessee had disclosed what was relevant and necessary for the purpose of making assessment - this is a clear case of change of opinion - HC
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