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...
Maintainability of deduction u/s. 80-IA on ‘Clean Development Mechanism’ (CDM) receipt by the assessee in respect of it’s two power generating units - true, the CERs, though intangible, are to be valued as inventories, but it is only on account of the protocol that they stand to be recognized separately and are valuable/realizable - Deduction not allowed - AT
Maintainability of deduction u/s. 80-IA on ‘Clean Development Mechanism’ (CDM) receipt by the assessee in respect of it’s two power generating units - true, the CERs, though intangible, are to be valued as inventories, but it is only on account of the protocol that they stand to be recognized separately and are valuable/realizable - Deduction not allowed - AT
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