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...
Cancelled GST registration for non-filing of returns over six months was considered fit for restoration where no allegation of fraud or unlawful activity was shown, the default was linked to financial hardship and Covid-19 disruption, and the taxpayer expressed readiness to clear statutory dues. Restoration was made conditional on the authorities first ascertaining and intimating the outstanding tax, interest and late fee or penalty, and on payment within the stipulated time; failing payment, the petition would stand dismissed.
Cancelled GST registration for non-filing of returns over six months was considered fit for restoration where no allegation of fraud or unlawful activity was shown, the default was linked to financial hardship and Covid-19 disruption, and the taxpayer expressed readiness to clear statutory dues. Restoration was made conditional on the authorities first ascertaining and intimating the outstanding tax, interest and late fee or penalty, and on payment within the stipulated time; failing payment, the petition would stand dismissed.
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