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 - where on account of delay in delivery of manufactured goods is liable to pay a lesser amount that the generically agreed price as a result of a clause (in the agreement), stipulating variation in the price, on account the liablility to “liquidated damages”, irrespective of whether the clause is titled “penalty” or “liquidated damages”, the resultant price would be the “transaction value” - AT
Valuation - where on account of delay in delivery of manufactured goods is liable to pay a lesser amount that the generically agreed price as a result of a clause (in the agreement), stipulating variation in the price, on account the liablility to “liquidated damages”, irrespective of whether the clause is titled “penalty” or “liquidated damages”, the resultant price would be the “transaction value” - AT
Note: It is a system-generated summary and is for quick reference only.