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...
Revision u/s 263 by CIT - profit attribution of a fixed place PE and the DAPE - Erroneous but not prejudicial to revenue order - Even if that computation of profit attribution, on the basis of the two taxpayer approach, is erroneous, in view of Hon’ble jurisdictional High Court decision, it cannot be said to be prejudicial to the interest of the revenue unless there is a categorical finding that the payment to the dependent agent is not an arm’s length price vis-à-vis functions performed, assets employed and risks assumed by the dependent agent. - AT
Revision u/s 263 by CIT - profit attribution of a fixed place PE and the DAPE - Erroneous but not prejudicial to revenue order - Even if that computation of profit attribution, on the basis of the two taxpayer approach, is erroneous, in view of Hon’ble jurisdictional High Court decision, it cannot be said to be prejudicial to the interest of the revenue unless there is a categorical finding that the payment to the dependent agent is not an arm’s length price vis-à-vis functions performed, assets employed and risks assumed by the dependent agent. - AT
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