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...
Disallowance of R & D units purchased as per Technical License Agreement - when the assessee has purchased a product in order to carry out improvements in its technology for future development and its sales thereafter, then such purchases cannot be said to be payment of royalty - the payment was not for use or use of any technology but for purchase of equipment for R&D purpose - no disallowance
Disallowance of R & D units purchased as per Technical License Agreement - when the assessee has purchased a product in order to carry out improvements in its technology for future development and its sales thereafter, then such purchases cannot be said to be payment of royalty - the payment was not for use or use of any technology but for purchase of equipment for R&D purpose - no disallowance
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