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...
Ad-hoc disallowance @ 20% of total site expenses - none of the authorities below as well as Ld. Sr. DR could bring on record any material to dislodge the claim of the assessee and substantiate the ad-hoc disallowance by adopting a rate of 20% for the same. - Additions deleted - AT
Ad-hoc disallowance @ 20% of total site expenses - none of the authorities below as well as Ld. Sr. DR could bring on record any material to dislodge the claim of the assessee and substantiate the ad-hoc disallowance by adopting a rate of 20% for the same. - Additions deleted - AT
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