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...
Sale of patent/ know-how known as “Profofal” - disputed amount is taxable as capital receipt/ gains u/s. 55 (2) - The assessee was not in the business of purchase and sale of patents, so the sale proceed of the assignment agreement could not be treated a revenue receipt. - AT
Sale of patent/ know-how known as “Profofal” - disputed amount is taxable as capital receipt/ gains u/s. 55 (2) - The assessee was not in the business of purchase and sale of patents, so the sale proceed of the assignment agreement could not be treated a revenue receipt. - AT
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