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...
AAAR declined to rule on the exemption claim for dredging and desilting services because the same transaction and period were already covered by a notice and adjudication order under section 73. It held that deciding the exemption issue in the advance ruling appeal could prejudice the statutory remedies available against that order, so judicial propriety required restraint. The Authority therefore left all substantive questions open, including the claimed exemption under Entry 3 or 3A, for determination in the appropriate appellate proceedings arising from the adjudication order.
AAAR declined to rule on the exemption claim for dredging and desilting services because the same transaction and period were already covered by a notice and adjudication order under section 73. It held that deciding the exemption issue in the advance ruling appeal could prejudice the statutory remedies available against that order, so judicial propriety required restraint. The Authority therefore left all substantive questions open, including the claimed exemption under Entry 3 or 3A, for determination in the appropriate appellate proceedings arising from the adjudication order.
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