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...
Relaxation under the FTP for genuine hardship requires a meaningful, reasoned consideration of the exporter's specific case, and administrative orders affecting rights must disclose cogent reasons rather than mechanical conclusions. The Court found that the authorities failed to address the claimed technical non-transmission of authorisation data, the asserted fulfilment of export obligations, and repeated requests for relief, and also denied a personal hearing despite specific requests. On that basis, the orders were set aside for non-application of mind and breach of natural justice, and the matter was remanded for fresh consideration with an effective hearing and a reasoned order.
Relaxation under the FTP for genuine hardship requires a meaningful, reasoned consideration of the exporter's specific case, and administrative orders affecting rights must disclose cogent reasons rather than mechanical conclusions. The Court found that the authorities failed to address the claimed technical non-transmission of authorisation data, the asserted fulfilment of export obligations, and repeated requests for relief, and also denied a personal hearing despite specific requests. On that basis, the orders were set aside for non-application of mind and breach of natural justice, and the matter was remanded for fresh consideration with an effective hearing and a reasoned order.
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