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...
Income attribution to trust - invoking section 61 - income taxable in the hands of the beneficiaries OR trust - revocable trust or not - Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1)
Income attribution to trust - invoking section 61 - income taxable in the hands of the beneficiaries OR trust - revocable trust or not - Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1)
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