Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Valuation of imported goods - related party transaction - the relationship did not influence the price - Rule 3(3)(a) & 3(3)(b) provide different means of establishing the acceptability of a transaction value - Rule 3(3)(b) cannot be made applicable while deciding the transaction value in the present case
Valuation of imported goods - related party transaction - the relationship did not influence the price - Rule 3(3)(a) & 3(3)(b) provide different means of establishing the acceptability of a transaction value - Rule 3(3)(b) cannot be made applicable while deciding the transaction value in the present case
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