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...
TDS u/s 194I - non deduction of TDS - compensation paid for the use of the building / premises / place of the members for construction activities - it would be highly unjustified to treat this amount as payment of rent and to make it liable for deduction of tax at source u/s 194-I. - invoking of provisions of section 40(a)(ia) is unjustified - AT
TDS u/s 194I - non deduction of TDS - compensation paid for the use of the building / premises / place of the members for construction activities - it would be highly unjustified to treat this amount as payment of rent and to make it liable for deduction of tax at source u/s 194-I. - invoking of provisions of section 40(a)(ia) is unjustified - AT
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