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...
Valuation - inclusion of royalty in assessable value - The running royalty is includible in the assessable value of blooms/bars cleared by the KCSSL, as the royalty is not in the nature of brand or IPR but in the nature of Techn0104' Transfer Fee for the purpose of Casting Specialty Alloy. - AT
Valuation - inclusion of royalty in assessable value - The running royalty is includible in the assessable value of blooms/bars cleared by the KCSSL, as the royalty is not in the nature of brand or IPR but in the nature of Techn0104' Transfer Fee for the purpose of Casting Specialty Alloy. - AT
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