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...
Higher rate of TDS @20% for non-furnishing of PAN u/s 206AA - whether cannot be at a rate prescribed u/s 206AA which is higher than the rate at which the relevant income is chargeable to tax under Act or DTAA - the scope of deduction of tax at source cannot be more than the tax liability under DTAA. - AT
Higher rate of TDS @20% for non-furnishing of PAN u/s 206AA - whether cannot be at a rate prescribed u/s 206AA which is higher than the rate at which the relevant income is chargeable to tax under Act or DTAA - the scope of deduction of tax at source cannot be more than the tax liability under DTAA. - AT
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