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...
Refrain from imposition of penalty - classification of imported goods - colour data projectors - It is only when there is any ambiguity in the Exemption Notification, that the Notification is required to be interpreted in favour of the Revenue - There is no ambiguity in the Exemption Notification dated 1st March, 2005 and indeed none has been pointed out by the Commissioner in the impugned order. - When penalty is not proposed in the Show cause notice (SCN), no penalty can be imposed - AT
Refrain from imposition of penalty - classification of imported goods - colour data projectors - It is only when there is any ambiguity in the Exemption Notification, that the Notification is required to be interpreted in favour of the Revenue - There is no ambiguity in the Exemption Notification dated 1st March, 2005 and indeed none has been pointed out by the Commissioner in the impugned order. - When penalty is not proposed in the Show cause notice (SCN), no penalty can be imposed - AT
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