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...
Addition u/s 37(1) - processing fees - the payment has not been made for acquiring a brand name, but for facilitating for acquisition of the brand name - by applying positive and negative tests, it is found that the expenditure is revenue in Nature - AT
Addition u/s 37(1) - processing fees - the payment has not been made for acquiring a brand name, but for facilitating for acquisition of the brand name - by applying positive and negative tests, it is found that the expenditure is revenue in Nature - AT
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