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...
Classification of services - erection of girders used in the construction of roads and bridges with the help of labour and equipment - supply of tangible goods services or not - The work order issued by M/s L & T Company describes the work as erection services and the payment in both the cases was linked to the number of girders erected. On going through the work contracts, the work performed by the appellants is essentially erection of girders. For this purpose, they may have used/mobilized equipment/labour. It is not coming forth from the work orders that the work orders were for supplies of any cranes or equipments. - AT
Classification of services - erection of girders used in the construction of roads and bridges with the help of labour and equipment - supply of tangible goods services or not - The work order issued by M/s L & T Company describes the work as erection services and the payment in both the cases was linked to the number of girders erected. On going through the work contracts, the work performed by the appellants is essentially erection of girders. For this purpose, they may have used/mobilized equipment/labour. It is not coming forth from the work orders that the work orders were for supplies of any cranes or equipments. - AT
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