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...
Assessable value - the “master charges” are collected for producing specific holograms for their clients and the masters are returned to the clients once the required supplies are made. When the appellant receive these charges as additional consideration for holograms, they are liable for inclusion in the assessable value. - AT
Assessable value - the “master charges” are collected for producing specific holograms for their clients and the masters are returned to the clients once the required supplies are made. When the appellant receive these charges as additional consideration for holograms, they are liable for inclusion in the assessable value. - AT
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