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 of demand - recovery notice during the pendency of the stay applications - Instruction No.1914 dated 02.12.1993 of the Board would make it clear that the stay petition filed with the AO must be disposed of within two weeks of the filing of petition by the taxpayer - recovery notice is obviously contrary to the Instructions and the Office Memorandum issued by the Board - calls for interference by this Court
Stay of demand - recovery notice during the pendency of the stay applications - Instruction No.1914 dated 02.12.1993 of the Board would make it clear that the stay petition filed with the AO must be disposed of within two weeks of the filing of petition by the taxpayer - recovery notice is obviously contrary to the Instructions and the Office Memorandum issued by the Board - calls for interference by this Court
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