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...
Unexplained investment - addition made on the basis of statements of third parties - no addition can be sustained on the basis of such oral admission of interested party without providing opportunity of cross examination and not supported by independent evidence. - AT
Unexplained investment - addition made on the basis of statements of third parties - no addition can be sustained on the basis of such oral admission of interested party without providing opportunity of cross examination and not supported by independent evidence. - AT
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