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...
Transfer of the 74% shares to the Singapore company - transactions were part of a design of 'treaty shopping' as having regard to the DTAA between India and Singapore, the capital gain would only be taxed at Singapore and not in India. - HC
Transfer of the 74% shares to the Singapore company - transactions were part of a design of 'treaty shopping' as having regard to the DTAA between India and Singapore, the capital gain would only be taxed at Singapore and not in India. - HC
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