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 u/s 2(22)(e) - deemed dividend - transfer of funds was between the companies on the direction of the Director - Substantial Share Holding - Before the Ld. CIT(A) it was inter alia submitted that the assessee had not paid but on the contrary it had received the sum from shareholder/director during the relevant year and, therefore, the provisions of section 2(22)(e) were not triggered. - CIT(A) rightly deleted the additions - AT
Addition u/s 2(22)(e) - deemed dividend - transfer of funds was between the companies on the direction of the Director - Substantial Share Holding - Before the Ld. CIT(A) it was inter alia submitted that the assessee had not paid but on the contrary it had received the sum from shareholder/director during the relevant year and, therefore, the provisions of section 2(22)(e) were not triggered. - CIT(A) rightly deleted the additions - AT
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