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...
Revision u/s 263 - Addition u/s 2(22)(e) - alleged loan & advances to concern - in assessment proceedings the Assessee had in fact placed audited statements which showed that sum received through AAIPL had been converted to shares allotted to AAIPL during AY 2014-15 - revenue has not been able to persuade this Court that the amount remained in the nature of loans and advances - no revision
Revision u/s 263 - Addition u/s 2(22)(e) - alleged loan & advances to concern - in assessment proceedings the Assessee had in fact placed audited statements which showed that sum received through AAIPL had been converted to shares allotted to AAIPL during AY 2014-15 - revenue has not been able to persuade this Court that the amount remained in the nature of loans and advances - no revision
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