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...
Depreciation on assets disallowed by authorities due to invoices bearing names of associate company and incorrect dates. Assessee contended ownership transferred via inter-office memos, incorrect invoice dates rectified, assets in use with payments made during assessment year. Business transfer agreement for purchase of running business caused delay in record date of acquisition. No employee cost as operations commenced with directors and assistance from associates, with billing arrangement of cost plus 15% markup to associated enterprise. When revenue accepted based on depreciation plus markup, no reason to deny cost. Authorities erred in disallowing depreciation. Decided in favor of assessee.
Depreciation on assets disallowed by authorities due to invoices bearing names of associate company and incorrect dates. Assessee contended ownership transferred via inter-office memos, incorrect invoice dates rectified, assets in use with payments made during assessment year. Business transfer agreement for purchase of running business caused delay in record date of acquisition. No employee cost as operations commenced with directors and assistance from associates, with billing arrangement of cost plus 15% markup to associated enterprise. When revenue accepted based on depreciation plus markup, no reason to deny cost. Authorities erred in disallowing depreciation. Decided in favor of assessee.
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