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...
Classification of services - It is for the respondents to carry out maintenance of these outfits and facilities and respondent can remove these outfits without assigning any reasons. The effective control of the outfits also thus remains with respondents and there is only right to use such outfits and facilities. The activity is more akin to supply of Tangible Goods Service.
Classification of services - It is for the respondents to carry out maintenance of these outfits and facilities and respondent can remove these outfits without assigning any reasons. The effective control of the outfits also thus remains with respondents and there is only right to use such outfits and facilities. The activity is more akin to supply of Tangible Goods Service.
Note: It is a system-generated summary and is for quick reference only.
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