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 - Whether providing space on roof for transportation of parcels/goods can be considered as "Business Support Service" by the Department? - The Tribunal examined the agreement terms and found that the primary activity of the appellant was to provide open space for storage of parcels at bus depots. The Tribunal noted that the appellant charged a license fee for this space, and the responsibility for managing the parcels rested with the company. It was held that this activity did not qualify as "Business Support Service."
Classification of services - Whether providing space on roof for transportation of parcels/goods can be considered as "Business Support Service" by the Department? - The Tribunal examined the agreement terms and found that the primary activity of the appellant was to provide open space for storage of parcels at bus depots. The Tribunal noted that the appellant charged a license fee for this space, and the responsibility for managing the parcels rested with the company. It was held that this activity did not qualify as "Business Support Service."
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