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...
Commission expenses paid to its holding company - Whether such payments were at arm's length or were for business expediency? - Revenue has accepted the identical expenses incurred by the assessee in the other assessment years - The disallowance was made on account of non-deduction of TDS under section 195 of the Act. Thus it can be inferred that the question of arm length and business expediency does not arise in the given facts and circumstances. - AT
Commission expenses paid to its holding company - Whether such payments were at arm's length or were for business expediency? - Revenue has accepted the identical expenses incurred by the assessee in the other assessment years - The disallowance was made on account of non-deduction of TDS under section 195 of the Act. Thus it can be inferred that the question of arm length and business expediency does not arise in the given facts and circumstances. - AT
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