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 writ petition challenging search, seizure, suspension of registration, bank attachment and related proceedings was not entertained because the controversy had already moved to the final adjudication orders under the statute. Once those final orders were passed, the petitioners were required to pursue the appellate remedy, where the same grounds remained available. The Court also noted that no appeal could be treated as pending because the stated appeal had not satisfied the statutory pre-deposit requirement. In these circumstances, there was no basis to invoke writ jurisdiction again over the same subject matter, and the petition was dismissed with liberty to challenge the final orders in appeal.
A writ petition challenging search, seizure, suspension of registration, bank attachment and related proceedings was not entertained because the controversy had already moved to the final adjudication orders under the statute. Once those final orders were passed, the petitioners were required to pursue the appellate remedy, where the same grounds remained available. The Court also noted that no appeal could be treated as pending because the stated appeal had not satisfied the statutory pre-deposit requirement. In these circumstances, there was no basis to invoke writ jurisdiction again over the same subject matter, and the petition was dismissed with liberty to challenge the final orders in appeal.
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