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...
Refund of TDS to the deductor - CIT(A) allowed the refund - as per the CBDT’s Circular No.2/2011 dated 2.04.2011, there is a procedure for the deductor to claim refund before the AO. - the order of the CIT(A) cannot be sustained and the credit for TDS cannot be allowed to the assessee in facts and circumstances of the case - AT
Refund of TDS to the deductor - CIT(A) allowed the refund - as per the CBDT’s Circular No.2/2011 dated 2.04.2011, there is a procedure for the deductor to claim refund before the AO. - the order of the CIT(A) cannot be sustained and the credit for TDS cannot be allowed to the assessee in facts and circumstances of the case - AT
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