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...
Valuation - relating parties - allowed 25% discount to sole buyer - the buyer is also holding company or a subsidiary company of the assessee. - Working in the same premises or the trading firm using the logo and name of the manufacturing firm by itself are of no consequence to consider the transaction value as tainted. - Demand set aside - AT
Valuation - relating parties - allowed 25% discount to sole buyer - the buyer is also holding company or a subsidiary company of the assessee. - Working in the same premises or the trading firm using the logo and name of the manufacturing firm by itself are of no consequence to consider the transaction value as tainted. - Demand set aside - AT
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