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...
Nature of expenditure - payment for non compete fee - the tenor of the agreement was only 18 months and it could not be stated that the assessee derived any enduring benefit due to the payment for obtaining certain commitments from payee and restricting himself from indulging in any competition or from weaning way the employees - revenue expenditure
Nature of expenditure - payment for non compete fee - the tenor of the agreement was only 18 months and it could not be stated that the assessee derived any enduring benefit due to the payment for obtaining certain commitments from payee and restricting himself from indulging in any competition or from weaning way the employees - revenue expenditure
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