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...
Extended period of limitation - Apart from a bald allegation there is no evidence adduced by department to establish supression or mis-statement of facts. The relied upon documents as stated in the show cause notice itself, establishes that appellant is not guilty of suppression of facts or mis-statement. - Demand set aside - AT
Extended period of limitation - Apart from a bald allegation there is no evidence adduced by department to establish supression or mis-statement of facts. The relied upon documents as stated in the show cause notice itself, establishes that appellant is not guilty of suppression of facts or mis-statement. - Demand set aside - AT
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