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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...
Mandatory statutory transfers of funds to the Central Government under section 23(2) of the Exim Act were treated as not constituting dividend, so section 115-O dividend distribution tax did not apply. The Tribunal followed its coordinate bench decision in the assessee's own later years, noted that the Revenue showed no change in facts or law, and upheld deletion of the tax demand. The Revenue's appeals for all years were dismissed.
Mandatory statutory transfers of funds to the Central Government under section 23(2) of the Exim Act were treated as not constituting dividend, so section 115-O dividend distribution tax did not apply. The Tribunal followed its coordinate bench decision in the assessee's own later years, noted that the Revenue showed no change in facts or law, and upheld deletion of the tax demand. The Revenue's appeals for all years were dismissed.
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