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...
Sale of asset - adventure in the nature of trade or would be the normal sale of assets attracting long term capital gain - Revenue’s stand is that pursuit of higher profit by itself would confer on the transaction the character of business venture. - HC
Sale of asset - adventure in the nature of trade or would be the normal sale of assets attracting long term capital gain - Revenue’s stand is that pursuit of higher profit by itself would confer on the transaction the character of business venture. - HC
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