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...
TP Adjustment - ALP of interest on receivables - no credit period was agreed between the parties - TPO should not calculate the collection period selectively which are beyond 90 days, he has to calculate the average of collection for the year under consideration of all the transactions - the adjustment only to the extent it crossed 90 days
TP Adjustment - ALP of interest on receivables - no credit period was agreed between the parties - TPO should not calculate the collection period selectively which are beyond 90 days, he has to calculate the average of collection for the year under consideration of all the transactions - the adjustment only to the extent it crossed 90 days
Note: It is a system-generated summary and is for quick reference only.
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