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 OR 192 - the payment made by the assessee towards reimbursement of expenses is in the nature of salary cost of the assigned employees subject to TDS u/s 192 of the Act, hence, cannot be treated as FTS u/s 9(1)(vii) of the Act and Article 12 of the tax treaty - No TDS liability u/s 195 - AT
TDS u/s 195 OR 192 - the payment made by the assessee towards reimbursement of expenses is in the nature of salary cost of the assigned employees subject to TDS u/s 192 of the Act, hence, cannot be treated as FTS u/s 9(1)(vii) of the Act and Article 12 of the tax treaty - No TDS liability u/s 195 - AT
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