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...
Smuggling - foreign currency - illicit export of currency - beneficial owners - The actual owner of the foreign currency having been identified, the concept of ‘beneficial owner’ does not arise. The Commissioner (Appeals), therefore, was not justified in reversing the finding recorded by the Additional Commissioner that the concept of ‘beneficial owner’ would not arise in the facts and circumstances of the case. - AT
Smuggling - foreign currency - illicit export of currency - beneficial owners - The actual owner of the foreign currency having been identified, the concept of ‘beneficial owner’ does not arise. The Commissioner (Appeals), therefore, was not justified in reversing the finding recorded by the Additional Commissioner that the concept of ‘beneficial owner’ would not arise in the facts and circumstances of the case. - AT
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