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...
Refund adjustment against a disputed tax demand was held unsustainable during pendency of the first appeal where the taxpayer had already deposited more than 50% of the demand. The Court found that coercive recovery, including garnishee action and adjustment of refunds for other assessment years, could not continue until disposal of the appeal. The revenue was directed to release the recovered amount with interest under section 244A, and no further coercive steps were permitted for the relevant assessment year pending appellate disposal.
Refund adjustment against a disputed tax demand was held unsustainable during pendency of the first appeal where the taxpayer had already deposited more than 50% of the demand. The Court found that coercive recovery, including garnishee action and adjustment of refunds for other assessment years, could not continue until disposal of the appeal. The revenue was directed to release the recovered amount with interest under section 244A, and no further coercive steps were permitted for the relevant assessment year pending appellate disposal.
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