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...
Frozen funds alleged to be proceeds of crime could not be released under an interim arrangement to meet employee salaries and statutory dues of another company identified as the primary accused. The liabilities were not those of the company holding the frozen funds, and the asserted arrangement between the two companies did not justify their use. The interim direction permitting release was set aside, while the pending appeal before the Tribunal remained open for independent adjudication on its merits and was directed to be decided expeditiously.
Frozen funds alleged to be proceeds of crime could not be released under an interim arrangement to meet employee salaries and statutory dues of another company identified as the primary accused. The liabilities were not those of the company holding the frozen funds, and the asserted arrangement between the two companies did not justify their use. The interim direction permitting release was set aside, while the pending appeal before the Tribunal remained open for independent adjudication on its merits and was directed to be decided expeditiously.
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