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...
Computation of Period of holding - Transferable Development Rights(TDR) - for the purpose of determination of period of holding, the holding of the TDR from the date of acquisition of property by the municipal authorities has to be considered, not from the date, when MOU was cancelled, then the period of holding of the asset is more than 36 months and hence, surplus is rightly assessable under the head lTCG
Computation of Period of holding - Transferable Development Rights(TDR) - for the purpose of determination of period of holding, the holding of the TDR from the date of acquisition of property by the municipal authorities has to be considered, not from the date, when MOU was cancelled, then the period of holding of the asset is more than 36 months and hence, surplus is rightly assessable under the head lTCG
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