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...
Permanent Establishment (‘PE’) in India - equipment PE - It cannot be denied that the ‘vessel’, on which equipments were placed and personnel was stationed, as fixed place of business through which business is carried on by assessee. Thus condition for PE stands satisfied
Permanent Establishment (‘PE’) in India - equipment PE - It cannot be denied that the ‘vessel’, on which equipments were placed and personnel was stationed, as fixed place of business through which business is carried on by assessee. Thus condition for PE stands satisfied
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