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...
Condonation of delay - delay of 583 days - Due to subsequent developments wherein the assessee runs a serious risk of prosecution where the penalty is confirmed, he was advised to file the present appeals - there exists sufficient and reasonable cause for condoning the delay of 583 days in filing the present appeals where substantial justice and technical considerations are pitted against each other, the cause of substantial justice deserved to be preferred. I
Condonation of delay - delay of 583 days - Due to subsequent developments wherein the assessee runs a serious risk of prosecution where the penalty is confirmed, he was advised to file the present appeals - there exists sufficient and reasonable cause for condoning the delay of 583 days in filing the present appeals where substantial justice and technical considerations are pitted against each other, the cause of substantial justice deserved to be preferred. I
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