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...
Delay in filing a GST appeal was treated as sufficiently explained where the order had been communicated to the Chartered Accountant, who failed to inform the taxpayer, and the mandatory pre-deposit was treated as substantial compliance with the appellate requirement. The note records that rejecting the appeal only on limitation, without considering the explanation, was viewed as a hyper-technical approach that could make the appellate remedy illusory, so the delay was condoned and the appeal was restored for hearing on merits. It also notes that the existing garnishee recovery, including freezing of bank accounts, was left in place until disposal of the appeal.
Delay in filing a GST appeal was treated as sufficiently explained where the order had been communicated to the Chartered Accountant, who failed to inform the taxpayer, and the mandatory pre-deposit was treated as substantial compliance with the appellate requirement. The note records that rejecting the appeal only on limitation, without considering the explanation, was viewed as a hyper-technical approach that could make the appellate remedy illusory, so the delay was condoned and the appeal was restored for hearing on merits. It also notes that the existing garnishee recovery, including freezing of bank accounts, was left in place until disposal of the appeal.
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