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...
TP adjustment - Determining the Arm's Length Price of international transactions in respect of "advisory services" - we adopt judicial consistency in the absence of any clinching distinction in both these assessment years involving the very issue of correctness of arm's length price adjustment in respect of advisory services. - TP adjustments deleted - AT
TP adjustment - Determining the Arm's Length Price of international transactions in respect of "advisory services" - we adopt judicial consistency in the absence of any clinching distinction in both these assessment years involving the very issue of correctness of arm's length price adjustment in respect of advisory services. - TP adjustments deleted - AT
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