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...
Valuation - deductions from the gross receipt of the billing - Appellant has not produced any evidence which can show that the print media had during the disputed period revised the rates, as a result of which there was a change in the rate of commission nor is there any serious challenge to the other findings.
Valuation - deductions from the gross receipt of the billing - Appellant has not produced any evidence which can show that the print media had during the disputed period revised the rates, as a result of which there was a change in the rate of commission nor is there any serious challenge to the other findings.
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