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...
Exemption u/s 11 - seeking benefit on the ground of mutuality in case of denial of benefit of section 11 by invoking section 13 - the assessee has clearly gave the details to the Assessing Officer that it has dealt only with the 140 non-members and details of their subscriptions, it shows that the assessee kept the record of dealing with the non-members. Therefore, we are inclined to remit this issue back to the file of Assessing Officer to evaluate the allowability of benefit under mutuality concept to the assessee.- AT
Exemption u/s 11 - seeking benefit on the ground of mutuality in case of denial of benefit of section 11 by invoking section 13 - the assessee has clearly gave the details to the Assessing Officer that it has dealt only with the 140 non-members and details of their subscriptions, it shows that the assessee kept the record of dealing with the non-members. Therefore, we are inclined to remit this issue back to the file of Assessing Officer to evaluate the allowability of benefit under mutuality concept to the assessee.- AT
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