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...
Correct head of income - treatment of interest income - The activity of advancing loans, in such a case, would become assessee’s business and naturally, the interest earned thereupon would constitute Business Income for the assessee. - The rule of consistency would demand that their being no change in facts or circumstances, the accepted position should not be disturbed. - AT
Correct head of income - treatment of interest income - The activity of advancing loans, in such a case, would become assessee’s business and naturally, the interest earned thereupon would constitute Business Income for the assessee. - The rule of consistency would demand that their being no change in facts or circumstances, the accepted position should not be disturbed. - AT
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