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 - Support Services of Business or Commerce or renting of immovable property - royalty / concession fee / lease charges received by the Port from KPPL represents consideration for providing services relatable to the taxable service - the arrangements between the parties was one of public-private partnership and was in the nature of a joint venture where two parties have got together to carry out a specific economic venture on a revenue sharing basis and there is no service rendered by Mormugao Port which can be taxed. - AT
Classification of services - Support Services of Business or Commerce or renting of immovable property - royalty / concession fee / lease charges received by the Port from KPPL represents consideration for providing services relatable to the taxable service - the arrangements between the parties was one of public-private partnership and was in the nature of a joint venture where two parties have got together to carry out a specific economic venture on a revenue sharing basis and there is no service rendered by Mormugao Port which can be taxed. - AT
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