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...
Depreciation by adopting the stamp value as per the provision of Section 50C - As per the scheme of the provision of Section 32 r.w.s 43(6) of the Act, which is a self contained scheme to compute the amount of deprecation allowable under the Act. According to our view, the reference to section 48 of the Act or the termful value of consideration are absent. Therefore, even otherwise, these two sections are not applicable in section 43(6) - AT
Depreciation by adopting the stamp value as per the provision of Section 50C - As per the scheme of the provision of Section 32 r.w.s 43(6) of the Act, which is a self contained scheme to compute the amount of deprecation allowable under the Act. According to our view, the reference to section 48 of the Act or the termful value of consideration are absent. Therefore, even otherwise, these two sections are not applicable in section 43(6) - AT
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