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 adjudicating authority has lost sight of the fact that the appellant's company is an artificial or non-human entity, cannot function or operate without involvement of the natural person i.e. the directors or the authorized persons. Therefore, we are of the considered view that the charges of guilt of 'collusion', 'wilful misstatement' or 'suppression of facts' cannot be levelled against the appellant, justifying invocation of the provisions of Section 28AAA of the Act - AT
The adjudicating authority has lost sight of the fact that the appellant's company is an artificial or non-human entity, cannot function or operate without involvement of the natural person i.e. the directors or the authorized persons. Therefore, we are of the considered view that the charges of guilt of 'collusion', 'wilful misstatement' or 'suppression of facts' cannot be levelled against the appellant, justifying invocation of the provisions of Section 28AAA of the Act - AT
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