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...
Waiver of interest u/s 234C - accruing of income of demerged company - demerger scheme was under contemplation does not mean that approval by the High Court was a certainty - hence till the approval was granted, demerged company could not have anticipated or contemplated flowing of the income in its coffers - Commissioner committed a serious error in rejecting the application for waiver of interest
Waiver of interest u/s 234C - accruing of income of demerged company - demerger scheme was under contemplation does not mean that approval by the High Court was a certainty - hence till the approval was granted, demerged company could not have anticipated or contemplated flowing of the income in its coffers - Commissioner committed a serious error in rejecting the application for waiver of interest
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