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...
Valuation of services - Joint venture - inclusion of "cost petroleum" and "profit petroleum" as per the Production sharing contract - inclusion of cash calls in the assessable value or not - Providing mining services to government - there is no service provider and service recipient relationship in the joint venture and the amounts in the nature of profit petroleum/cost petroleum/ cash calls are not consideration for services. - AT
Valuation of services - Joint venture - inclusion of "cost petroleum" and "profit petroleum" as per the Production sharing contract - inclusion of cash calls in the assessable value or not - Providing mining services to government - there is no service provider and service recipient relationship in the joint venture and the amounts in the nature of profit petroleum/cost petroleum/ cash calls are not consideration for services. - AT
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