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...
The clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law.
The clarificatory amendment governing computation of the limitation period under transfer pricing provisions was applied, and an order passed on 01.11.2019 was treated as within time; the CIT(A)'s finding that the TPO's order was time-barred was reversed. Because the CIT(A) had not examined the adjustment on research support services on merits, that issue was remanded for fresh adjudication. A fresh claim for India-USA DTAA relief against dividend distribution tax was not admitted, as it required foundational facts and documents, including residency evidence, not already on record and therefore was not a pure question of law.
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