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...
DTAA – Since contract was for less than six months, it becomes absolutely clear that the assessee did not have a permanent establishment in India as per article 5(3) of the treaty - HC
DTAA – Since contract was for less than six months, it becomes absolutely clear that the assessee did not have a permanent establishment in India as per article 5(3) of the treaty - HC
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