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...
Addition by invoking the provisions of Section 56(2)(viia) which is applicable from 01/06/2010 - nothing is brought on record to substantiate that the shares were transferred in the month of November 2010, on the contrary the annual return filed by the Seller of the shares clearly established that the transfer of the shares took place on 10/05/2010 - no addition
Addition by invoking the provisions of Section 56(2)(viia) which is applicable from 01/06/2010 - nothing is brought on record to substantiate that the shares were transferred in the month of November 2010, on the contrary the annual return filed by the Seller of the shares clearly established that the transfer of the shares took place on 10/05/2010 - no addition
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