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...
DFIA benefits - validity of transfer of DFIA issued under SION E-5 (Biscuits) - There is no actual user condition in existence prior to the issue of PN 84 - There is no merits in the arguement of revenue that the amendments in the DFIA licenses have been obtained through fraudulent means and suppression of facts before the licensing authorities. - AT
DFIA benefits - validity of transfer of DFIA issued under SION E-5 (Biscuits) - There is no actual user condition in existence prior to the issue of PN 84 - There is no merits in the arguement of revenue that the amendments in the DFIA licenses have been obtained through fraudulent means and suppression of facts before the licensing authorities. - AT
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