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...
Mischief of 'royalty' u/s 9(1) - payment made for transfer of the right to use the software/computer programme in respect of the copyrights falls within the mischief of 'royalty' - HC
Mischief of 'royalty' u/s 9(1) - payment made for transfer of the right to use the software/computer programme in respect of the copyrights falls within the mischief of 'royalty' - HC
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