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...
Supply of DG sets on hire basis - this is the case of supply of tangible goods for use, with legal right of possession and effective control vesting with the hirer, required to be treated as "deemed sale of goods", hence cannot be considered as "supply of tangible goods for use of service" - AT
Supply of DG sets on hire basis - this is the case of supply of tangible goods for use, with legal right of possession and effective control vesting with the hirer, required to be treated as "deemed sale of goods", hence cannot be considered as "supply of tangible goods for use of service" - AT
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