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 - activity of preparation of site for the power plant - It has been found as a fact that the work order in the present case, involves both supply of services as also goods. It is, therefore, a composite contract. In view of the decisions of the Supreme Court in Larsen & Toubro it has to be held that the services performed by the appellant under the work order would fall in the category of “works contract‘ service and not “site formation‘ service. - AT
Classification of services - activity of preparation of site for the power plant - It has been found as a fact that the work order in the present case, involves both supply of services as also goods. It is, therefore, a composite contract. In view of the decisions of the Supreme Court in Larsen & Toubro it has to be held that the services performed by the appellant under the work order would fall in the category of “works contract‘ service and not “site formation‘ service. - AT
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