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...
Addition solely on the basis of statement of official of assessee as recorded during the survey action - The AO has not investigated the issue and only insisted on the disclosure made by assessee. As seen that the ld.CIT(A) after considering the submission of assessee, accounts of MDHPL and the fact that no amount on account of marketing fees from the contract of assessee with MDHPL was realised. - No additions - AT
Addition solely on the basis of statement of official of assessee as recorded during the survey action - The AO has not investigated the issue and only insisted on the disclosure made by assessee. As seen that the ld.CIT(A) after considering the submission of assessee, accounts of MDHPL and the fact that no amount on account of marketing fees from the contract of assessee with MDHPL was realised. - No additions - AT
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