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...
Royalty receipt - transfer of right to use a computer software - The Judgement by the Appellate Tribunal addressed the dispute regarding the classification of income and the applicable tax rate for the appellant. The Tribunal found in favor of the appellant, ruling that the income received should be considered royalty income under Sec. 9(1)(vi) of the Act and taxed at 10%.
Royalty receipt - transfer of right to use a computer software - The Judgement by the Appellate Tribunal addressed the dispute regarding the classification of income and the applicable tax rate for the appellant. The Tribunal found in favor of the appellant, ruling that the income received should be considered royalty income under Sec. 9(1)(vi) of the Act and taxed at 10%.
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