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...
Non adjudication of grounds by tribunal - Liability of TDS u/s 194C - Tribunal ought to have rendered a finding on the grounds raised by the assessee with regard to the applicability of Section 194C on the IUC paid to the other telecom operators and remanded on alternative ground - without any finding on the applicability of Section 194C the order passed by the Tribunal should be and shall be read as an open remand to the AO
Non adjudication of grounds by tribunal - Liability of TDS u/s 194C - Tribunal ought to have rendered a finding on the grounds raised by the assessee with regard to the applicability of Section 194C on the IUC paid to the other telecom operators and remanded on alternative ground - without any finding on the applicability of Section 194C the order passed by the Tribunal should be and shall be read as an open remand to the AO
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