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...
Advance ruling was barred where the same input tax credit question was already pending in enforcement proceedings against the applicant. The Authority held that, under the proviso to section 98(2), an advance ruling cannot be admitted on a question already pending in proceedings under the Act in the applicant's case. Because the jurisdictional authority had already initiated action on admissibility of input tax credit for construction of the hotel building, and the applicant did not dispute that fact, the application was rejected without any ruling on the merits.
Advance ruling was barred where the same input tax credit question was already pending in enforcement proceedings against the applicant. The Authority held that, under the proviso to section 98(2), an advance ruling cannot be admitted on a question already pending in proceedings under the Act in the applicant's case. Because the jurisdictional authority had already initiated action on admissibility of input tax credit for construction of the hotel building, and the applicant did not dispute that fact, the application was rejected without any ruling on the merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
