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...
Refund could not be denied merely because the Chartered Accountant's certificate was not in the prescribed format or did not mention the year, where the lower authority did not question the genuineness of the claim and the defect was only formal. The Tribunal held that the Board circular format was only indicative, not mandatory, and that substantial compliance was sufficient. The rejection of refund on this technical ground was therefore unsustainable. The common appellate order was set aside and the appeals were allowed with consequential benefits as per law.
Refund could not be denied merely because the Chartered Accountant's certificate was not in the prescribed format or did not mention the year, where the lower authority did not question the genuineness of the claim and the defect was only formal. The Tribunal held that the Board circular format was only indicative, not mandatory, and that substantial compliance was sufficient. The rejection of refund on this technical ground was therefore unsustainable. The common appellate order was set aside and the appeals were allowed with consequential benefits as per law.
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