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...
Transportation and insurance charges recovered for moving goods were not taxable as business support service where the appellant was not acting as a goods transport agency issuing consignment notes; transportation by road by a person other than a GTA remained outside the levy, and the insurance element was treated as bundled with transport. Reverse charge on accounting services supplied to the Ethiopian branch also failed because the services were received and used in Ethiopia, with the branch and Indian office treated as separate permanent establishments. The extended period of limitation was unavailable because the demand rested on disclosed balance-sheet figures, so the related penalty, interest, and remaining penalties also fell.
Transportation and insurance charges recovered for moving goods were not taxable as business support service where the appellant was not acting as a goods transport agency issuing consignment notes; transportation by road by a person other than a GTA remained outside the levy, and the insurance element was treated as bundled with transport. Reverse charge on accounting services supplied to the Ethiopian branch also failed because the services were received and used in Ethiopia, with the branch and Indian office treated as separate permanent establishments. The extended period of limitation was unavailable because the demand rested on disclosed balance-sheet figures, so the related penalty, interest, and remaining penalties also fell.
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