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...
A show cause notice issued in disregard of a binding and unchallenged advance ruling was treated as non-est because the ruling had attained finality between the parties and remained operative under the CGST framework. The Court held that, where the invalidity of the notice was apparent on the face of the record, the petitioner was not required to first reply to the notice or pursue the statutory remedy. It therefore exercised writ jurisdiction under Article 226 and quashed the notice as lacking foundation.
A show cause notice issued in disregard of a binding and unchallenged advance ruling was treated as non-est because the ruling had attained finality between the parties and remained operative under the CGST framework. The Court held that, where the invalidity of the notice was apparent on the face of the record, the petitioner was not required to first reply to the notice or pursue the statutory remedy. It therefore exercised writ jurisdiction under Article 226 and quashed the notice as lacking foundation.
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