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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...
GST assessment was set aside and remitted because the taxpayer's defence raised factual questions that had not been examined: whether input tax credit was inadvertently claimed under the IGST column, whether it was voluntarily reversed, and whether that reversal affected the liability imposed. The Court required the authority to give the taxpayer an opportunity to file a detailed response with supporting documents and to adjudicate the matter afresh in light of that defence and the statutory provisions. The taxpayer was also left free to seek revocation of suspension of registration by separate representation.
GST assessment was set aside and remitted because the taxpayer's defence raised factual questions that had not been examined: whether input tax credit was inadvertently claimed under the IGST column, whether it was voluntarily reversed, and whether that reversal affected the liability imposed. The Court required the authority to give the taxpayer an opportunity to file a detailed response with supporting documents and to adjudicate the matter afresh in light of that defence and the statutory provisions. The taxpayer was also left free to seek revocation of suspension of registration by separate representation.
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