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...
Status of assessee as "AOP" instead of "partnership firm" - The assessee firm was comprised of four individual partners who were representing their respective firms - There was no justification on the part of the lower authorities to have recharacterized the assessee firm i.e. a firm comprising of individual partners (representing their respective firms) as an "AOP". - AT
Status of assessee as "AOP" instead of "partnership firm" - The assessee firm was comprised of four individual partners who were representing their respective firms - There was no justification on the part of the lower authorities to have recharacterized the assessee firm i.e. a firm comprising of individual partners (representing their respective firms) as an "AOP". - AT
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