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...
In GST scrutiny, once ASMT-10 is issued and a reply is filed, the proceedings must proceed to ASMT-12 or to DRC-01A followed by DRC-01; ASMT-13 is confined to non-filers under Section 62, so its use after ASMT-10 and ASMT-11 was procedurally invalid. On that defect, the DRC-07 orders for one registration were set aside, treated as DRC-01 notices, and remitted for de novo adjudication, with the pendency period excluded for limitation. For the other registration, the inspection material justified invocation of the extended period under Section 74, and the writ petitions were dismissed because DRC-01A, DRC-01 and assessment orders were properly issued.
In GST scrutiny, once ASMT-10 is issued and a reply is filed, the proceedings must proceed to ASMT-12 or to DRC-01A followed by DRC-01; ASMT-13 is confined to non-filers under Section 62, so its use after ASMT-10 and ASMT-11 was procedurally invalid. On that defect, the DRC-07 orders for one registration were set aside, treated as DRC-01 notices, and remitted for de novo adjudication, with the pendency period excluded for limitation. For the other registration, the inspection material justified invocation of the extended period under Section 74, and the writ petitions were dismissed because DRC-01A, DRC-01 and assessment orders were properly issued.
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