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...
Refund of excess dividend Distribution Tax (DDT) paid - The Appellate Tribunal held that DTAA does not apply when a domestic company pays DDT under Section 115-O of the Act. Refund of excess DDT based on DTAA provisions was denied, following a decision by the ITAT Mumbai Special Bench.
Refund of excess dividend Distribution Tax (DDT) paid - The Appellate Tribunal held that DTAA does not apply when a domestic company pays DDT under Section 115-O of the Act. Refund of excess DDT based on DTAA provisions was denied, following a decision by the ITAT Mumbai Special Bench.
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