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...
Management Fees paid to its holding company - once assessee had established its case of availment of said services, disallowance on the basis that invoices were serially numbered and paid at the close of the year is not permissible
Management Fees paid to its holding company - once assessee had established its case of availment of said services, disallowance on the basis that invoices were serially numbered and paid at the close of the year is not permissible
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