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...
Addition under Section 41(1) - The loan transactions were on the capital account and the writing off the loan was also on capital account and did not find place in the Profit and Loss Account - Thus the cessation of the liability by itself would not lead to the attraction of Section 41(1) - HC
Addition under Section 41(1) - The loan transactions were on the capital account and the writing off the loan was also on capital account and did not find place in the Profit and Loss Account - Thus the cessation of the liability by itself would not lead to the attraction of Section 41(1) - HC
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