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...
Deemed dividend under section 2(22)(e) - assessee claimed that advances were received as business advances, however, the assessee failed to produce any documentary evidence in support of this submission - the basic conditions of section 2(22)(e) of the Act are satisfied in the present case. - Additions confirmed - AT
Deemed dividend under section 2(22)(e) - assessee claimed that advances were received as business advances, however, the assessee failed to produce any documentary evidence in support of this submission - the basic conditions of section 2(22)(e) of the Act are satisfied in the present case. - Additions confirmed - AT
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