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...
Interpretation of statute - classification of service - the assessee has not relied upon any authority to say that the specific exclusion of one head or one commercial activity can generally be read in relation to other specific heads. Such an interpretation is also not supported by any principle of statutory construction and therefore has to fail.
Interpretation of statute - classification of service - the assessee has not relied upon any authority to say that the specific exclusion of one head or one commercial activity can generally be read in relation to other specific heads. Such an interpretation is also not supported by any principle of statutory construction and therefore has to fail.
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