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...
Extended period of Limitation - There is no obligation cast on the appellant to intimate the Department on each and every transaction. The appellant have filed regular returns with the Department and have maintained proper records. Further, the appellant have obtained statement of “cost of production‟ duly certified by the Cost Accountant - The elements of suppression, mis-statement, fraud, etc. are not coming out from the facts and circumstances.
Extended period of Limitation - There is no obligation cast on the appellant to intimate the Department on each and every transaction. The appellant have filed regular returns with the Department and have maintained proper records. Further, the appellant have obtained statement of “cost of production‟ duly certified by the Cost Accountant - The elements of suppression, mis-statement, fraud, etc. are not coming out from the facts and circumstances.
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