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...
Bright Line Test - Whether ITAT has erred in relying upon the judgment of this Court in Sony Ericsson Mobile Communication [2015 (3) TMI 580 - DELHI HIGH COURT] as the Department has not accepted the decision passed in Sony Ericsson (supra) and has preferred an appeal against the said decision before the Supreme Court - Held No - Revenue appeal dismissed - HC
Bright Line Test - Whether ITAT has erred in relying upon the judgment of this Court in Sony Ericsson Mobile Communication [2015 (3) TMI 580 - DELHI HIGH COURT] as the Department has not accepted the decision passed in Sony Ericsson (supra) and has preferred an appeal against the said decision before the Supreme Court - Held No - Revenue appeal dismissed - HC
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