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...
Import of services - certain reimbursements made to the foreign entities for the services received under Reverse Charge Mechanism - networking charges and technical services - The appellant argued that reimbursements for services performed outside India should not be taxed. The Tribunal agreed, referencing the Intercontinental Consultants & Technocrats case, which held that only the consideration for the taxable service should be valued and assessed, not additional expenses.
Import of services - certain reimbursements made to the foreign entities for the services received under Reverse Charge Mechanism - networking charges and technical services - The appellant argued that reimbursements for services performed outside India should not be taxed. The Tribunal agreed, referencing the Intercontinental Consultants & Technocrats case, which held that only the consideration for the taxable service should be valued and assessed, not additional expenses.
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