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...
The Madras HC held that the ninety-day period in Regulation 17(1) of the Customs Brokers Licensing Regulations, 2018 for issuing a show cause notice after receipt of the offence report is mandatory. Relying on its earlier binding decisions, the Court rejected the contrary view that the provision is merely directory. Because the impugned show cause notice was issued beyond the prescribed period, it was vitiated and set aside, and the consequential inquiry report founded on that notice also could not survive.
The Madras HC held that the ninety-day period in Regulation 17(1) of the Customs Brokers Licensing Regulations, 2018 for issuing a show cause notice after receipt of the offence report is mandatory. Relying on its earlier binding decisions, the Court rejected the contrary view that the provision is merely directory. Because the impugned show cause notice was issued beyond the prescribed period, it was vitiated and set aside, and the consequential inquiry report founded on that notice also could not survive.
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