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...
Wavier Pre-deposit - alternate and efficacious remedy - no explanation as to why petitioners chose to remain absent before the Adjudicating Authority or to avail of opportunity for cross-examination - nothing demonstrated as to why the petitioners cannot avail the alternate remedy of appeal and neither pleaded nor elaborated that pre-deposit constitutes a hardship, not a fit case to ignore the mandate of Section 129E
Wavier Pre-deposit - alternate and efficacious remedy - no explanation as to why petitioners chose to remain absent before the Adjudicating Authority or to avail of opportunity for cross-examination - nothing demonstrated as to why the petitioners cannot avail the alternate remedy of appeal and neither pleaded nor elaborated that pre-deposit constitutes a hardship, not a fit case to ignore the mandate of Section 129E
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