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...
Concessional electricity charges under Clause 16(a) of the 2019 Industrial Policy were held to apply only to new industrial enterprises, while existing enterprises undertaking substantial expansion fell under Clause 16(b) and could claim only the rebate linked to incremental consumption. The 29.04.2022 amendment substituting "eligible" with "new" in Clause 16(a) and aligning Clause 16(b) with substantial expansion was treated as clarificatory and retrospective, except for the newly introduced three-year duration under Clause 16(b), which operated prospectively. The respondent therefore had no entitlement to Clause 16(a) concession, and promissory estoppel could not create a benefit beyond the Policy's true scope.
Concessional electricity charges under Clause 16(a) of the 2019 Industrial Policy were held to apply only to new industrial enterprises, while existing enterprises undertaking substantial expansion fell under Clause 16(b) and could claim only the rebate linked to incremental consumption. The 29.04.2022 amendment substituting "eligible" with "new" in Clause 16(a) and aligning Clause 16(b) with substantial expansion was treated as clarificatory and retrospective, except for the newly introduced three-year duration under Clause 16(b), which operated prospectively. The respondent therefore had no entitlement to Clause 16(a) concession, and promissory estoppel could not create a benefit beyond the Policy's true scope.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
