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...
Accrual of Income in India - Royalty - right to use the software - overriding effect to the DTAA - from reading of the terms of the agreements, it is clear that there was no right to use the computer software - income of the assessee which was brought to tax by the Revenue authorities cannot be brought to tax and the same is directed to be deleted. - AT
Accrual of Income in India - Royalty - right to use the software - overriding effect to the DTAA - from reading of the terms of the agreements, it is clear that there was no right to use the computer software - income of the assessee which was brought to tax by the Revenue authorities cannot be brought to tax and the same is directed to be deleted. - AT
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