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...
Deduction u/s. 10A - export sales - non-receipt in convertible foreign exchange - Even for the sake of discussion, the plea of the assessee of converting the outstanding sale proceeds into overseas direct investment to be treated as compliance of provision of section 10A(3) then also it cannot be accepted as there is no proper approval of Reserve Bank of India for capitalization of outstanding export sale proceeds. - AT
Deduction u/s. 10A - export sales - non-receipt in convertible foreign exchange - Even for the sake of discussion, the plea of the assessee of converting the outstanding sale proceeds into overseas direct investment to be treated as compliance of provision of section 10A(3) then also it cannot be accepted as there is no proper approval of Reserve Bank of India for capitalization of outstanding export sale proceeds. - AT
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