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 - the case of enhancement of value are merely based on NIDB data, when such documents relating NIDB data were not even supplied to the appellants, thus not following principles of Natural Justice, value cannot be enhanced - AT
Valuation - the case of enhancement of value are merely based on NIDB data, when such documents relating NIDB data were not even supplied to the appellants, thus not following principles of Natural Justice, value cannot be enhanced - AT
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