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...
Availability of an appellate remedy under the Customs Act requires parties challenging orders-in-original to pursue the statutory appeal rather than seek writ relief on the merits. Attached bank accounts may be released pending that appeal where Revenue is secured through appropriation of the statutory pre-deposit from the attached funds and an unconditional bank guarantee for the remaining demand. On fulfilment of both conditions, the accounts may be operated to enable business continuity; failure to file the appeal or provide the required security permits appropriation of the entire amount due.
Availability of an appellate remedy under the Customs Act requires parties challenging orders-in-original to pursue the statutory appeal rather than seek writ relief on the merits. Attached bank accounts may be released pending that appeal where Revenue is secured through appropriation of the statutory pre-deposit from the attached funds and an unconditional bank guarantee for the remaining demand. On fulfilment of both conditions, the accounts may be operated to enable business continuity; failure to file the appeal or provide the required security permits appropriation of the entire amount due.
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