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...
Valuation of Vessel - Whether the transaction value of the vessel is to be priced mentioned in the original MOA or the reduced price indicated in the addendum? - the genuineness and the necessity of reduction in the price are required to be scrutinised very carefully - the Ld. Commissioner (Appeals) passed the impugned order only by relying the finding of lower adjudicating authority - In the instant case, the Ld. Commissioner (Appeals) has not examined the genuineness of the addendum, and has proceeded to reject the appeal of the appellant. - Matter restored back - AT
Valuation of Vessel - Whether the transaction value of the vessel is to be priced mentioned in the original MOA or the reduced price indicated in the addendum? - the genuineness and the necessity of reduction in the price are required to be scrutinised very carefully - the Ld. Commissioner (Appeals) passed the impugned order only by relying the finding of lower adjudicating authority - In the instant case, the Ld. Commissioner (Appeals) has not examined the genuineness of the addendum, and has proceeded to reject the appeal of the appellant. - Matter restored back - AT
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