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...
Levy of Dividend distribution tax (DDT) at the rate of 20.36% u/s 115O - claim of assessee that it should have been levied at the rate of 15% in terms of Article 10 of DTAA between India and Thailand - The ITAT dismisses the appeal regarding the rate of DDT, citing a previous decision that shareholders have no influence on the levy of DDT, which is an additional tax charged on distributed profits of the company.
Levy of Dividend distribution tax (DDT) at the rate of 20.36% u/s 115O - claim of assessee that it should have been levied at the rate of 15% in terms of Article 10 of DTAA between India and Thailand - The ITAT dismisses the appeal regarding the rate of DDT, citing a previous decision that shareholders have no influence on the levy of DDT, which is an additional tax charged on distributed profits of the company.
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