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...
Monetary limits continue to govern departmental filing of appeals, applications and special leave petitions under the UPGST framework: GSTAT matters below Rs. 20,00,000, High Court matters below Rs. 1,00,00,000 and Supreme Court matters below Rs. 2,00,00,000 are ordinarily not to be pursued. The limits do not apply where a provision, rule, regulation, order, notification, direction or circular is treated as unconstitutional, or where the dispute concerns valuation, classification, refunds, place of supply, recurring interpretative issues, adverse costs or observations, or any matter the Commissioner considers necessary in the interest of justice or revenue. Zonal Law Committees are to review first appellate orders, meet at least twice monthly, record minutes and identify cases for appeal or best-practice circulation.
Monetary limits continue to govern departmental filing of appeals, applications and special leave petitions under the UPGST framework: GSTAT matters below Rs. 20,00,000, High Court matters below Rs. 1,00,00,000 and Supreme Court matters below Rs. 2,00,00,000 are ordinarily not to be pursued. The limits do not apply where a provision, rule, regulation, order, notification, direction or circular is treated as unconstitutional, or where the dispute concerns valuation, classification, refunds, place of supply, recurring interpretative issues, adverse costs or observations, or any matter the Commissioner considers necessary in the interest of justice or revenue. Zonal Law Committees are to review first appellate orders, meet at least twice monthly, record minutes and identify cases for appeal or best-practice circulation.
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