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...
Condonation of delay beyond the ordinarily condonable period for a GST appeal was considered appropriate where rectification proceedings were not the sole explanation and the tax levy was disputed on factual grounds requiring adjudication on merits. The delay dismissal was set aside, the appeal was restored, and merits were left open for decision after an opportunity of hearing. The approach accords with treatment of a similar factual situation involving delayed GST appellate proceedings.
Condonation of delay beyond the ordinarily condonable period for a GST appeal was considered appropriate where rectification proceedings were not the sole explanation and the tax levy was disputed on factual grounds requiring adjudication on merits. The delay dismissal was set aside, the appeal was restored, and merits were left open for decision after an opportunity of hearing. The approach accords with treatment of a similar factual situation involving delayed GST appellate proceedings.
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