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...
Transfer of right to use goods - Hiring of Charter Vessel for dredging activity -Appellant enjoys full right to exclusion of others. During the period, neither the owner can use the vessel nor can the owner transfer the right to use of the vessel to another person - there exist no hesitation to hold that the appellant enjoys right to use the vessel to the exclusion of the owner.
Transfer of right to use goods - Hiring of Charter Vessel for dredging activity -Appellant enjoys full right to exclusion of others. During the period, neither the owner can use the vessel nor can the owner transfer the right to use of the vessel to another person - there exist no hesitation to hold that the appellant enjoys right to use the vessel to the exclusion of the owner.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
