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...
Classification of service - Appellants are only managing the services and the consultation is only in relation to IT and therefore, in our opinion, the activities are not covered by “Management Consultancy Service” at all - AT
Classification of service - Appellants are only managing the services and the consultation is only in relation to IT and therefore, in our opinion, the activities are not covered by “Management Consultancy Service” at all - AT
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