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...
Transfer pricing adjustment rejected assessee's comparable companies in TP study analysis. Directed TPO to examine if companies are functionally comparable, apply applicable filters, and include if comparable. Rejection of comparable solely on higher turnover set aside, directed consistent turnover filter application. Deferred receivables treated as international transaction, remanded to apply bank rate after allowing 60-day credit period. Partly allowed.
Transfer pricing adjustment rejected assessee's comparable companies in TP study analysis. Directed TPO to examine if companies are functionally comparable, apply applicable filters, and include if comparable. Rejection of comparable solely on higher turnover set aside, directed consistent turnover filter application. Deferred receivables treated as international transaction, remanded to apply bank rate after allowing 60-day credit period. Partly allowed.
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