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...
Classification of services - manpower supply services or Business Auxiliary Service (BAS) - The tenor of the contract clearly indicate that the Agreement entered into by the appellant’s is a “Labour Supply Contract” and so the services rendered would fall under “Manpower Recruitment or Supply Agency” service - demand of tax upheld. - AT
Classification of services - manpower supply services or Business Auxiliary Service (BAS) - The tenor of the contract clearly indicate that the Agreement entered into by the appellant’s is a “Labour Supply Contract” and so the services rendered would fall under “Manpower Recruitment or Supply Agency” service - demand of tax upheld. - AT
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