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 - The Tribunal established that amounts received as incentives, productivity-linked bonuses, and boarding incentives from airlines are taxable under the category of "Air Travel Agent Services" and not under BAS. It was also held that commissions received from other travel agents or General Sales Agents (GSAs) and from the appellant's own branches do not constitute taxable services under BAS. - AT
Classification of services - The Tribunal established that amounts received as incentives, productivity-linked bonuses, and boarding incentives from airlines are taxable under the category of "Air Travel Agent Services" and not under BAS. It was also held that commissions received from other travel agents or General Sales Agents (GSAs) and from the appellant's own branches do not constitute taxable services under BAS. - AT
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