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...
Deemed dividend u/s 2(22)(e) - receipt of advance against agreement to sale the property to the company - subsequently agreement was cancelled due to fall in market price - so called ‘fall in market value of property and subsequent change in circumstances’ would not have come in the way of alleged sale transaction of the subject property. - additions confirmed.
Deemed dividend u/s 2(22)(e) - receipt of advance against agreement to sale the property to the company - subsequently agreement was cancelled due to fall in market price - so called ‘fall in market value of property and subsequent change in circumstances’ would not have come in the way of alleged sale transaction of the subject property. - additions confirmed.
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