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...
Disallowance of Commission Expenses - prior period expenditure - due to poor sales performance, security was forfeited and adjusted - on request the same restored and commission paid in subsequent year after deduction of TDS - Thus, the findings of the ld CIT(A) holding that payment was on account of royalty and a prior period expense cannot be sustained. - AT
Disallowance of Commission Expenses - prior period expenditure - due to poor sales performance, security was forfeited and adjusted - on request the same restored and commission paid in subsequent year after deduction of TDS - Thus, the findings of the ld CIT(A) holding that payment was on account of royalty and a prior period expense cannot be sustained. - AT
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