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...
Stay petition - demand raised by AO on three issue, TP adjustment,attribution and royalty - TP adjustment and attribution issue relating to the other assessment years being set aside by the Tribunal - hence the issue contested before the Tribunal by the revenue was only relating to the royalty issue and amount of stay determined based on royalty - ITAT rightly quantified amount for stay
Stay petition - demand raised by AO on three issue, TP adjustment,attribution and royalty - TP adjustment and attribution issue relating to the other assessment years being set aside by the Tribunal - hence the issue contested before the Tribunal by the revenue was only relating to the royalty issue and amount of stay determined based on royalty - ITAT rightly quantified amount for stay
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