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...
Movement of goods from Maharashtra to Buffer Depots and Satellite Depots in other States was treated as stock transfer, not an inter-State sale, because the Agreement and MOU did not create a binding prior contract fixing quantity, specification or determinative price at dispatch. The concluded sales arose only at depot level on receipt and acceptance of purchase orders, and the goods moved as mixed inventory replenishment under stock transfer documents. Form F declarations for 2008-09 could not be rejected for omitting lorry receipt numbers and vehicle details where the lorry receipts themselves proved dispatch; those omissions were only minor procedural defects.
Movement of goods from Maharashtra to Buffer Depots and Satellite Depots in other States was treated as stock transfer, not an inter-State sale, because the Agreement and MOU did not create a binding prior contract fixing quantity, specification or determinative price at dispatch. The concluded sales arose only at depot level on receipt and acceptance of purchase orders, and the goods moved as mixed inventory replenishment under stock transfer documents. Form F declarations for 2008-09 could not be rejected for omitting lorry receipt numbers and vehicle details where the lorry receipts themselves proved dispatch; those omissions were only minor procedural defects.
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