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...
Deemed dividend u/s.2(22)(e) - the company has given some payments to the third party on behalf of the assessee, but said payments have been subsequently re-paid by the assessee or his family members either on the same day or within a short period i.e. less than one month without there being any outstanding balance in the books of accounts of the company. Therefore, transactions between the assessee and company cannot be treated as loan or advance within the meaning of provisions of Sec.2(22)(e) - AT
Deemed dividend u/s.2(22)(e) - the company has given some payments to the third party on behalf of the assessee, but said payments have been subsequently re-paid by the assessee or his family members either on the same day or within a short period i.e. less than one month without there being any outstanding balance in the books of accounts of the company. Therefore, transactions between the assessee and company cannot be treated as loan or advance within the meaning of provisions of Sec.2(22)(e) - AT
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