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...
Business Auxiliary Services - promotion or marketing of goods produced or provided by or belonging to the client - transfer of right to use - The imposition of restrictions or conditions in respect of the usage and consumption of the concentrate, by the seller cannot alter that position. Hence there are no merit in the submission that this transaction was not a truncation of sale but only “transfer to use”. - AT
Business Auxiliary Services - promotion or marketing of goods produced or provided by or belonging to the client - transfer of right to use - The imposition of restrictions or conditions in respect of the usage and consumption of the concentrate, by the seller cannot alter that position. Hence there are no merit in the submission that this transaction was not a truncation of sale but only “transfer to use”. - AT
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