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...
Allowable busniss expenses - Diversion of income - Though the amount has been received by the assessee, the same is collected on behalf of the joint venture - It is the settled law that the accounting entries are not determinative of the actual nature of the transaction; it is the substance that prevails. - AT
Allowable busniss expenses - Diversion of income - Though the amount has been received by the assessee, the same is collected on behalf of the joint venture - It is the settled law that the accounting entries are not determinative of the actual nature of the transaction; it is the substance that prevails. - AT
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