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...
Natural justice justified writ interference where additional objections and supporting documents were refused in insolvency proceedings after the corporate debtor had filed its original reply. The Tribunal had power to receive subsequent pleadings with leave under the procedural rules, read with its inherent powers, and the refusal on the ground that no such provision existed was unsustainable. The short time for the original reply explained the later filing, and the alternative-remedy objection did not bar relief because the refusal was procedurally unfair. The impugned order was set aside and the Tribunal was directed to consider the additional objections and documents.
Natural justice justified writ interference where additional objections and supporting documents were refused in insolvency proceedings after the corporate debtor had filed its original reply. The Tribunal had power to receive subsequent pleadings with leave under the procedural rules, read with its inherent powers, and the refusal on the ground that no such provision existed was unsustainable. The short time for the original reply explained the later filing, and the alternative-remedy objection did not bar relief because the refusal was procedurally unfair. The impugned order was set aside and the Tribunal was directed to consider the additional objections and documents.
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