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...
Disallowance of project expenses - Addition on the ground as no project-wise accounting was available and no work-in-progress was reported - As the assessee is engaged in the business of consultancy services definitely there can be some overlap of the expenses between two years. However that does not give any rise to the AO to disallow the expenditure @10% and treat it as work in progress. - AT
Disallowance of project expenses - Addition on the ground as no project-wise accounting was available and no work-in-progress was reported - As the assessee is engaged in the business of consultancy services definitely there can be some overlap of the expenses between two years. However that does not give any rise to the AO to disallow the expenditure @10% and treat it as work in progress. - AT
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