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...
Deemed capital gains by invoking the provisions of section 50D - there was no justification on the part of the authorities below to doubt or dispute the said consideration as claimed to be mutually agreed by the assessee-company to arrive at the conclusion that the consideration received or accruing as a result of the transfer of the two flats was not ascertainable or could not be determined without even making any inquiry whatsoever with the concerned transferees. - AT
Deemed capital gains by invoking the provisions of section 50D - there was no justification on the part of the authorities below to doubt or dispute the said consideration as claimed to be mutually agreed by the assessee-company to arrive at the conclusion that the consideration received or accruing as a result of the transfer of the two flats was not ascertainable or could not be determined without even making any inquiry whatsoever with the concerned transferees. - AT
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