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...
Special Additional Duty refund limitation under an amending customs exemption notification is addressed in relation to a claim rejected solely for filing beyond one year. The limitation was treated as requiring read-down because subordinate legislation could not impose a time bar affecting substantive refund rights without applying a statutory limitation under the parent enactment. A contrary High Court view was noted, but the refund claim was treated as covered by the decisions supporting read-down. The time-bar rejection was set aside, with consequential relief in accordance with law.
Special Additional Duty refund limitation under an amending customs exemption notification is addressed in relation to a claim rejected solely for filing beyond one year. The limitation was treated as requiring read-down because subordinate legislation could not impose a time bar affecting substantive refund rights without applying a statutory limitation under the parent enactment. A contrary High Court view was noted, but the refund claim was treated as covered by the decisions supporting read-down. The time-bar rejection was set aside, with consequential relief in accordance with law.
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