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...
Clandestine manufacture and clearance - The Revenue cannot rest its case on the sole basis of the statements without taking into account the surrounding circumstances. As such in the absence of any reference by the said deponents, to the fact of passing of quality control test about a week ago and in the absence of any admission that the same were not entered with any malafide intention to remove them clandestinely. - AT
Clandestine manufacture and clearance - The Revenue cannot rest its case on the sole basis of the statements without taking into account the surrounding circumstances. As such in the absence of any reference by the said deponents, to the fact of passing of quality control test about a week ago and in the absence of any admission that the same were not entered with any malafide intention to remove them clandestinely. - AT
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