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...
The doctrine of merger applies where the Appellate Tribunal has passed a final order in an appeal: prior interlocutory orders, including a recall order, merge into the final appellate order and cease to have independent existence. A writ petition challenging the recall order therefore cannot survive once the final order is challenged through the available statutory tax appeal. The challenge to the final order must be pursued in that statutory appellate remedy, and the writ petition was dismissed.
The doctrine of merger applies where the Appellate Tribunal has passed a final order in an appeal: prior interlocutory orders, including a recall order, merge into the final appellate order and cease to have independent existence. A writ petition challenging the recall order therefore cannot survive once the final order is challenged through the available statutory tax appeal. The challenge to the final order must be pursued in that statutory appellate remedy, and the writ petition was dismissed.
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