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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...
Since the AO made the disallowance only on the ground that Form 15G/15H were not submitted to the ld. Commissioner in time, only penalty proceedings can be initiated under section 272A(2)(f) and no disallowance can be made under section 40(a)(ia) - AT
Since the AO made the disallowance only on the ground that Form 15G/15H were not submitted to the ld. Commissioner in time, only penalty proceedings can be initiated under section 272A(2)(f) and no disallowance can be made under section 40(a)(ia) - AT
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