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...
TDS u/s 195 - Disallowance of commission income - there was no requirement for the assessee to deduct tax at source on such payments made to non-resident agents based out of UK, without anything to substantiate that such agents had a permanent establishment in India or that the services were rendered India or that the agents had visited India in connection with providing such services. - AT
TDS u/s 195 - Disallowance of commission income - there was no requirement for the assessee to deduct tax at source on such payments made to non-resident agents based out of UK, without anything to substantiate that such agents had a permanent establishment in India or that the services were rendered India or that the agents had visited India in connection with providing such services. - AT
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