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...
Applicability of section 33AB(7) - The provisions of section 33AB (7) uses the expression ‘being utilised’ - assessee had paid substantial portion of the proforma invoice value as advance before 31.3.2012 and had included the same in the utilization statement - action of the revenue in bringing to tax the deemed income in terms of section 33AB(7) deserves to be deleted - AT
Applicability of section 33AB(7) - The provisions of section 33AB (7) uses the expression ‘being utilised’ - assessee had paid substantial portion of the proforma invoice value as advance before 31.3.2012 and had included the same in the utilization statement - action of the revenue in bringing to tax the deemed income in terms of section 33AB(7) deserves to be deleted - AT
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