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...
Transfer pricing adjustment - interest rate charged by the assessee in the international transactions was much higher than the LIBOR rates - interest charged in the loan transaction in question has to be held to be as at arm’s length - AT
Transfer pricing adjustment - interest rate charged by the assessee in the international transactions was much higher than the LIBOR rates - interest charged in the loan transaction in question has to be held to be as at arm’s length - AT
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