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...
Doctrine of mutuality - The first four incomes i.e. Pay & Park Charges and rent from Vodafone, BSNL and Idea towers cannot be considered to be covered by doctrine of mutuality. - Interest income on Fixed Deposit also fails to pass the test.
Doctrine of mutuality - The first four incomes i.e. Pay & Park Charges and rent from Vodafone, BSNL and Idea towers cannot be considered to be covered by doctrine of mutuality. - Interest income on Fixed Deposit also fails to pass the test.
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