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...
Nature of rental income - Income from House Property or Business income - Deemed owner - assessee was entitled to have access to operate, manage and maintain the Licensed Space at the Specified Area during the License Period - No semblance of any characteristics of transactions for which Section 53A of the Act is applicable and there is no question of assessee being a deemed owner, so as to account for rent as income from property and not business income. - AT
Nature of rental income - Income from House Property or Business income - Deemed owner - assessee was entitled to have access to operate, manage and maintain the Licensed Space at the Specified Area during the License Period - No semblance of any characteristics of transactions for which Section 53A of the Act is applicable and there is no question of assessee being a deemed owner, so as to account for rent as income from property and not business income. - AT
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