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...
Penalty under section 122(1A) of the CGST Act must be imposed consistently with the person identified in the show-cause notice. Specified penalties were proposed against the petitioner, while the separate section 122(1A) penalty was proposed against its handler/operator; nevertheless, both penalties were imposed on the petitioner. As this mixing of proposed penalties was not specifically controverted, the penalty order was quashed and remanded for fresh adjudication after hearing the petitioner, with other issues left open.
Penalty under section 122(1A) of the CGST Act must be imposed consistently with the person identified in the show-cause notice. Specified penalties were proposed against the petitioner, while the separate section 122(1A) penalty was proposed against its handler/operator; nevertheless, both penalties were imposed on the petitioner. As this mixing of proposed penalties was not specifically controverted, the penalty order was quashed and remanded for fresh adjudication after hearing the petitioner, with other issues left open.
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