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...
Disallowance of royalty - capital OR revenue expenditure - The ownership/ proprietary rights in the technical know-how continue to vest in lithe censor and the assessee is not authorised to transfer, assign or convey the know how/technical information to any third party - payment was for mere use of technical know-how, not resulting in any enduring benefit - revenue exp.
Disallowance of royalty - capital OR revenue expenditure - The ownership/ proprietary rights in the technical know-how continue to vest in lithe censor and the assessee is not authorised to transfer, assign or convey the know how/technical information to any third party - payment was for mere use of technical know-how, not resulting in any enduring benefit - revenue exp.
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