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...
Admissibility of appeals - grant of ITC - merely because certain documents may have been brought on record may not itself be sufficient to grant ITC - once claim had been rejected by the AO, the appellate authority was obliged to record a positive finding after due appraisal of the evidence on record or calling remand report - failure leads to order erroneous and are premature - remanded
Admissibility of appeals - grant of ITC - merely because certain documents may have been brought on record may not itself be sufficient to grant ITC - once claim had been rejected by the AO, the appellate authority was obliged to record a positive finding after due appraisal of the evidence on record or calling remand report - failure leads to order erroneous and are premature - remanded
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