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...
Sections 73 and 74 of the GST law do not bar a consolidated show cause notice or consolidated adjudication covering multiple financial years. Limitation must be tested separately for each financial year, but that does not deprive the proper officer of jurisdiction to issue one common notice or pass one common order. The scheme also permits statements for other periods on the same grounds, supporting multi-period proceedings. If one included year is time-barred, the entire proceeding is not void; the barred portion can be severed because each financial year is a distinct cause of action.
Sections 73 and 74 of the GST law do not bar a consolidated show cause notice or consolidated adjudication covering multiple financial years. Limitation must be tested separately for each financial year, but that does not deprive the proper officer of jurisdiction to issue one common notice or pass one common order. The scheme also permits statements for other periods on the same grounds, supporting multi-period proceedings. If one included year is time-barred, the entire proceeding is not void; the barred portion can be severed because each financial year is a distinct cause of action.
Note: It is a system-generated summary and is for quick reference only.
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