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...
LTCG - period of holding - purchase of share directly between the parties and not through stock exchange - as per documents filed, since the actual delivery of shares took place along with transfer deeds/contract bills, so that date should be considered the date of transfer i.e 30.03.2012 - scrips was admittedly sold on 16.08.2013 after more than 12 months - LTCG
LTCG - period of holding - purchase of share directly between the parties and not through stock exchange - as per documents filed, since the actual delivery of shares took place along with transfer deeds/contract bills, so that date should be considered the date of transfer i.e 30.03.2012 - scrips was admittedly sold on 16.08.2013 after more than 12 months - LTCG
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