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...
Disallowance of excessive licence fee paid to M/s Uflex Ltd. - increase of the license fee from ₹ 50 Lac per month to ₹ 2 Crore per month - the issue of increasing the license fee is considered by all the authorities in the preceding years therefore, in the immediately preceding year, we hold that the CIT(A) was fully justified in allowing the license fee.
Disallowance of excessive licence fee paid to M/s Uflex Ltd. - increase of the license fee from ₹ 50 Lac per month to ₹ 2 Crore per month - the issue of increasing the license fee is considered by all the authorities in the preceding years therefore, in the immediately preceding year, we hold that the CIT(A) was fully justified in allowing the license fee.
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