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...
Computation of deduction u/s 10A - exclusion of expenditure incurred in foreign currency in export of software, from the purview of 'Export Turnover' - the artificial split up of the transaction by the Assessing Officer, that too without any materials on his file, is wholly unsustainable
Computation of deduction u/s 10A - exclusion of expenditure incurred in foreign currency in export of software, from the purview of 'Export Turnover' - the artificial split up of the transaction by the Assessing Officer, that too without any materials on his file, is wholly unsustainable
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