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...
GTA Service - denial of benefit of 75% abatement in the absence of any declaration furnished by the transport agencies - There is no merit in the submissions that even without declaration as stipulated in the notification, the assessee was entitled to such exemption, is over simplifying or glossing over the conditions itself, which cannot be permitted. - Tribunal was perfectly justified in denying such exemption.
GTA Service - denial of benefit of 75% abatement in the absence of any declaration furnished by the transport agencies - There is no merit in the submissions that even without declaration as stipulated in the notification, the assessee was entitled to such exemption, is over simplifying or glossing over the conditions itself, which cannot be permitted. - Tribunal was perfectly justified in denying such exemption.
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