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...
Assessment of Firm as AOP - in terms of section 167 the share of the members of AOP are indeterminate - In such case the whole of the income of such an AOP is to be taxed at the maximum marginal rate, as being an AOP with indeterminate share - HC
Assessment of Firm as AOP - in terms of section 167 the share of the members of AOP are indeterminate - In such case the whole of the income of such an AOP is to be taxed at the maximum marginal rate, as being an AOP with indeterminate share - HC
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