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...
The interest is evidently and explicitly payable under Rule 6(3A) clause (e) read with Rule 14 of CCR 2004. The interest has indeed been demanded under Rule 14 of CCR 2004. Merely because they have also not mentioned Rule 6(3A) in the Show Cause Notice, it does not vitiate the entire demand of interest.
The interest is evidently and explicitly payable under Rule 6(3A) clause (e) read with Rule 14 of CCR 2004. The interest has indeed been demanded under Rule 14 of CCR 2004. Merely because they have also not mentioned Rule 6(3A) in the Show Cause Notice, it does not vitiate the entire demand of interest.
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