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 in export of finished goods to AE - comparison of the price charged to non–AEs located in India with the price charged to AEs in foreign countries cannot be considered to be a CUP to determine the ALP being situated in different geographical locations, as there may be various factors/reasons which could have influenced the price charged - CUP rejected
TP adjustment in export of finished goods to AE - comparison of the price charged to non–AEs located in India with the price charged to AEs in foreign countries cannot be considered to be a CUP to determine the ALP being situated in different geographical locations, as there may be various factors/reasons which could have influenced the price charged - CUP rejected
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