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 - quantum of discount to be reduced - appellants are remunerating the re-sellers with 1% trade discount included in the 30% trade discount. The effective trade discount is only 29% - Demand confirmed for normal period of limitation.
Valuation - quantum of discount to be reduced - appellants are remunerating the re-sellers with 1% trade discount included in the 30% trade discount. The effective trade discount is only 29% - Demand confirmed for normal period of limitation.
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