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...
Short computation of TCS - Period of limitation for submission of Form 27C - the claim of the ld. Counsel for the assessee that there is no time limit prescribed for obtaining declaration Form 27C is not correct, and it cannot be obtained and furnished by the whimps and fancy of the assessee. - the assessee could not even obtain declaration in Form 27C within the reasonable time and claimed to have obtained said form at the time of assessment proceedings. - AT
Short computation of TCS - Period of limitation for submission of Form 27C - the claim of the ld. Counsel for the assessee that there is no time limit prescribed for obtaining declaration Form 27C is not correct, and it cannot be obtained and furnished by the whimps and fancy of the assessee. - the assessee could not even obtain declaration in Form 27C within the reasonable time and claimed to have obtained said form at the time of assessment proceedings. - AT
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