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...
Intellectual property rights service - the payment made to Vemmar SRL, Itay cannot be considered as share of its profit of the joint venture - since the services are being provided outside India, recipient is liable to tax.
Intellectual property rights service - the payment made to Vemmar SRL, Itay cannot be considered as share of its profit of the joint venture - since the services are being provided outside India, recipient is liable to tax.
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