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...
TP adjustment of Technical Assistance fees and project management services not claimed as expenditure but capitalized as project - capital transactions are outside the purview of TP mechanism but at time of claiming depreciation it is relevant otherwise same will be allowed only on revised value.
TP adjustment of Technical Assistance fees and project management services not claimed as expenditure but capitalized as project - capital transactions are outside the purview of TP mechanism but at time of claiming depreciation it is relevant otherwise same will be allowed only on revised value.
Note: It is a system-generated summary and is for quick reference only.