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...
Interim access to frozen funds under the PMLA may be permitted for essential employee salaries and statutory dues where the liabilities are genuine, the subsidiary prima facie owes funds to its holding company, and safeguards preserve the attached assets. Verified payments of TDS and GST avoid compelled statutory defaults while benefiting the Central Government. Limited access was permitted for verified outstanding salaries and statutory dues, subject to submission of payment details, verification and bank-authorisation safeguards, without addressing the merits of the pending appeals.
Interim access to frozen funds under the PMLA may be permitted for essential employee salaries and statutory dues where the liabilities are genuine, the subsidiary prima facie owes funds to its holding company, and safeguards preserve the attached assets. Verified payments of TDS and GST avoid compelled statutory defaults while benefiting the Central Government. Limited access was permitted for verified outstanding salaries and statutory dues, subject to submission of payment details, verification and bank-authorisation safeguards, without addressing the merits of the pending appeals.
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