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...
Exemption u/s 11 - Entitled to the registration u/s 12AA - when the original application was filed by the respondent it was a fledgling organization. Today another 2-3 years have passed and therefore, the Commissioner would have the benefit of seeing the records of the respondent to verify whether it does indeed meet the test of Section 12AA or not. - Order of ITAT directing the CIT to consider additions documents sustained.
Exemption u/s 11 - Entitled to the registration u/s 12AA - when the original application was filed by the respondent it was a fledgling organization. Today another 2-3 years have passed and therefore, the Commissioner would have the benefit of seeing the records of the respondent to verify whether it does indeed meet the test of Section 12AA or not. - Order of ITAT directing the CIT to consider additions documents sustained.
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