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...
Capital loss - sale of shares to sister concern when the transaction for sale to an outside buyer for a much higher price is being processed - the transaction is neither fraudulent nor a colourable device - Authorities cannot enter into the shoe of the assessee to decide the prudence of commercial expediency of a particular transaction.
Capital loss - sale of shares to sister concern when the transaction for sale to an outside buyer for a much higher price is being processed - the transaction is neither fraudulent nor a colourable device - Authorities cannot enter into the shoe of the assessee to decide the prudence of commercial expediency of a particular transaction.
Note: It is a system-generated summary and is for quick reference only.