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...
Continuation of a Look Out Circular after completion of investigation, with no pending prosecution or court proceeding, was held to be unjustified where the record contained no concrete material showing that the person's departure would harm India's sovereignty, security, integrity, strategic or economic interests, or that larger public interest required restraint. The Court applied Article 21 and proportionality, noting that travel abroad is part of personal liberty and that less restrictive safeguards were available. The LOC was quashed as arbitrary and disproportionate, subject to filing a notarized undertaking to appear if prosecuted, cooperate, furnish contact details and not surrender the Indian passport for the stipulated period.
Continuation of a Look Out Circular after completion of investigation, with no pending prosecution or court proceeding, was held to be unjustified where the record contained no concrete material showing that the person's departure would harm India's sovereignty, security, integrity, strategic or economic interests, or that larger public interest required restraint. The Court applied Article 21 and proportionality, noting that travel abroad is part of personal liberty and that less restrictive safeguards were available. The LOC was quashed as arbitrary and disproportionate, subject to filing a notarized undertaking to appear if prosecuted, cooperate, furnish contact details and not surrender the Indian passport for the stipulated period.
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