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...
Clandestine Removal - reliability of statements - sufficiency of evidence or not - In a serious case such as evasion of duty by fraud, the degree of appreciation of evidence has to be higher than in a case of allegation of mere delay in payment of duty though in both cases the evidence has to be appreciated on the preponderance of probability. - there is enough evidence to establish the case put forth by department. The role of the Managing Director in such activity is also clear. - AT
Clandestine Removal - reliability of statements - sufficiency of evidence or not - In a serious case such as evasion of duty by fraud, the degree of appreciation of evidence has to be higher than in a case of allegation of mere delay in payment of duty though in both cases the evidence has to be appreciated on the preponderance of probability. - there is enough evidence to establish the case put forth by department. The role of the Managing Director in such activity is also clear. - AT
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