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...
Validity of re-assessment proceedings - UP VAT - It is only on the basis of the fact that the royalty amount has not been clarified in the invoices that a decision has been taken to reopen the assessment. This by itself is not sufficient and a good ground when the assessing authority was possessed with all material at the time of initial assessment and nothing material was concealed from him. - HC
Validity of re-assessment proceedings - UP VAT - It is only on the basis of the fact that the royalty amount has not been clarified in the invoices that a decision has been taken to reopen the assessment. This by itself is not sufficient and a good ground when the assessing authority was possessed with all material at the time of initial assessment and nothing material was concealed from him. - HC
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