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...
For the purposes of deduction of tax u/s 194LBB, or u/s 194LBC the “rates in force” in relation to an assessment year or financial year shall mean the rate or rates of income-tax specified in this behalf in the Finance Act of the relevant year or rate or rates of incometax specified in an agreement entered into by the Central Government u/s 90 or notified by the Central Government u/s 90A, whichever is applicable.
For the purposes of deduction of tax u/s 194LBB, or u/s 194LBC the “rates in force” in relation to an assessment year or financial year shall mean the rate or rates of income-tax specified in this behalf in the Finance Act of the relevant year or rate or rates of incometax specified in an agreement entered into by the Central Government u/s 90 or notified by the Central Government u/s 90A, whichever is applicable.
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