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...
Income estimation applying GP Rate - AO neither pointed out any defect in the books of accounts nor rejected u/s 145(2) - addition without verification of various expenditure and giving any benefit of difference in the business model, product dealt with, geographical area operated in etc. and merely compared the GP of other entities is not permissible
Income estimation applying GP Rate - AO neither pointed out any defect in the books of accounts nor rejected u/s 145(2) - addition without verification of various expenditure and giving any benefit of difference in the business model, product dealt with, geographical area operated in etc. and merely compared the GP of other entities is not permissible
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