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...
Discrepancies between export turnover reported in Forms GSTR-3B and GSTR-1 require a registered taxable person to receive an opportunity to produce documents establishing the nature of the transactions and substantiating export turnover. Where non-participation in GST adjudication is explained and applicable Board Circulars contemplate such documentary verification, an ex parte determination may require fresh consideration. The appellate rejection based on inability to condone delay beyond 120 days and the adjudication order were quashed, with the proceedings restored for reconsideration after production of supporting documents and issuance of a reasoned order.
Discrepancies between export turnover reported in Forms GSTR-3B and GSTR-1 require a registered taxable person to receive an opportunity to produce documents establishing the nature of the transactions and substantiating export turnover. Where non-participation in GST adjudication is explained and applicable Board Circulars contemplate such documentary verification, an ex parte determination may require fresh consideration. The appellate rejection based on inability to condone delay beyond 120 days and the adjudication order were quashed, with the proceedings restored for reconsideration after production of supporting documents and issuance of a reasoned order.
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