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...
Bail in GST prosecutions involving alleged fraudulent input tax credit depends on whether detention is necessary to secure trial attendance or prevent interference with justice. Criminal antecedents alone do not justify refusal without material indicating a risk of absconding, witness intimidation, evidence tampering, repetition of offences, or other obstruction. Pre-trial detention is not punitive, particularly where investigation is complete, the prosecution rests on documentary evidence, and trial may be delayed. The offence being triable by a Magistrate and carrying limited maximum punishment, together with the absence of assessment proceedings that could affect the alleged contravention, supported release on conditions protecting the trial and prosecution evidence.
Bail in GST prosecutions involving alleged fraudulent input tax credit depends on whether detention is necessary to secure trial attendance or prevent interference with justice. Criminal antecedents alone do not justify refusal without material indicating a risk of absconding, witness intimidation, evidence tampering, repetition of offences, or other obstruction. Pre-trial detention is not punitive, particularly where investigation is complete, the prosecution rests on documentary evidence, and trial may be delayed. The offence being triable by a Magistrate and carrying limited maximum punishment, together with the absence of assessment proceedings that could affect the alleged contravention, supported release on conditions protecting the trial and prosecution evidence.
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