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...
Forfeiture of properties of the first respondent - COFEPOSA - properties and the illegal earnings - The notice proceeds on the footing that once the relationship between the noticee and the detenue is established the property in the hands of the noticee would automatically become illegally acquired property. - a link or nexus is totally absent and no effort or endeavour has been made to establish such link or nexus - HC
Forfeiture of properties of the first respondent - COFEPOSA - properties and the illegal earnings - The notice proceeds on the footing that once the relationship between the noticee and the detenue is established the property in the hands of the noticee would automatically become illegally acquired property. - a link or nexus is totally absent and no effort or endeavour has been made to establish such link or nexus - HC
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