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...
Unexplained investment in land - the appellant had entered into a deal to purchase this land and subsequent gone to get it registered; the eventual seller to her had registered it earlier as a purchaser; she was purported to be clearly 50% owner; no one can believe that she was entitled to such a benefit without spending a single rupee. - AT
Unexplained investment in land - the appellant had entered into a deal to purchase this land and subsequent gone to get it registered; the eventual seller to her had registered it earlier as a purchaser; she was purported to be clearly 50% owner; no one can believe that she was entitled to such a benefit without spending a single rupee. - AT
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