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...
Purchase of Technical know-how - Covered under section 9(l)(vi) of Income Tax Act, 1961 and treated as royalty - The Seller had sold, assigned, conveyed and transferred to assessee its entire right, title, interest and ownership in the asset - not taxable in view of DTAA - AT
Purchase of Technical know-how - Covered under section 9(l)(vi) of Income Tax Act, 1961 and treated as royalty - The Seller had sold, assigned, conveyed and transferred to assessee its entire right, title, interest and ownership in the asset - not taxable in view of DTAA - AT
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