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...
Denial of refund claim - in the second proceedings original authority has found that a portion of the refund claim was time-barred - once all the refund claims and their fate had attained finality in the order of the Commissioner (Appeals), no further action could have been taken - AT
Denial of refund claim - in the second proceedings original authority has found that a portion of the refund claim was time-barred - once all the refund claims and their fate had attained finality in the order of the Commissioner (Appeals), no further action could have been taken - AT
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