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 - related person or not - a proprietorship concern and a Private Limited company are not related person - even if two are held to be related, the price to any independent buyer of similar quantity only can be adopted under Rule 11 - Demand fails on both count.
Valuation - related person or not - a proprietorship concern and a Private Limited company are not related person - even if two are held to be related, the price to any independent buyer of similar quantity only can be adopted under Rule 11 - Demand fails on both count.
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