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 - Contract for carrying out not only site grading but also construction of Roads, Boundary wall, Drains lines and associated works for crude oil terminal of Bina Refinery Project - The appellant’s activity is not covered by the definition of “site formation and clearance, excavation and earth moving and demolition service. The majority of work relates to civil work in the nature for construction of road, boundary wall and drainage lines. The essential character of this composite work is reflected as that of construction service. - AT
Classification of services - Contract for carrying out not only site grading but also construction of Roads, Boundary wall, Drains lines and associated works for crude oil terminal of Bina Refinery Project - The appellant’s activity is not covered by the definition of “site formation and clearance, excavation and earth moving and demolition service. The majority of work relates to civil work in the nature for construction of road, boundary wall and drainage lines. The essential character of this composite work is reflected as that of construction service. - AT
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