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...
Income from royalty - bookings arising from India, the payment for Altea Reservation System (ARS) is made by the British Airways for the use of system for the purpose of business in India and for the purpose of earning income from India - Mere amendment to Section 9(1)(vi) cannot result in a change. - the Finance Act, 2012 will not affect Article 12 of the DTAAs - AT
Income from royalty - bookings arising from India, the payment for Altea Reservation System (ARS) is made by the British Airways for the use of system for the purpose of business in India and for the purpose of earning income from India - Mere amendment to Section 9(1)(vi) cannot result in a change. - the Finance Act, 2012 will not affect Article 12 of the DTAAs - AT
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