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...
Difference between the value reflected in ST3 returns and as shown in the Income ledger of the appellant - there is otherwise no evidence on record to reflect any clandestine providing of services or undervaluing the services - stay granted - AT
Difference between the value reflected in ST3 returns and as shown in the Income ledger of the appellant - there is otherwise no evidence on record to reflect any clandestine providing of services or undervaluing the services - stay granted - AT
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