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...
Royalty income earned from the OEMs on network equipment -In view of the specific clauses in the agreement between OEM's and Indian parties, it is clear that the software didn't have an independent use and is a integral part of the hardware without which the hardware cannot function. The software supplied was a copyrighted article and not a copyright right - Not taxable u/s 9 - AT
Royalty income earned from the OEMs on network equipment -In view of the specific clauses in the agreement between OEM's and Indian parties, it is clear that the software didn't have an independent use and is a integral part of the hardware without which the hardware cannot function. The software supplied was a copyrighted article and not a copyright right - Not taxable u/s 9 - AT
Note: It is a system-generated summary and is for quick reference only.
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