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...
Location of supplier and 'place of business' depend on where the supplier ordinarily runs the business; therefore the place from which supplies are made determines the location of services - outcome: services are located at the Head Office (HO). Whether FSEs constitute an agent or create a place of business was addressed by noting FSEs are employees who do not contract with customers independently and can be withdrawn by the HO - outcome: FSE presence in Odisha is not a separate place of business or fixed establishment. Registration liability follows the supplier location; outcome: no separate GST registration required in Odisha.
Location of supplier and 'place of business' depend on where the supplier ordinarily runs the business; therefore the place from which supplies are made determines the location of services - outcome: services are located at the Head Office (HO). Whether FSEs constitute an agent or create a place of business was addressed by noting FSEs are employees who do not contract with customers independently and can be withdrawn by the HO - outcome: FSE presence in Odisha is not a separate place of business or fixed establishment. Registration liability follows the supplier location; outcome: no separate GST registration required in Odisha.
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