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...
Benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - petitioner had not filed returns during the relevant period - The stand of the Department is in fact beneficial to the appellant especially since the Department had the option of treating the petitioner's declarations as 'never made', and thereby denying it the benefits under the scheme and initiating proceedings for recovery of the tax amount, together with penalty and interest in accordance with the statutory provisions. - HC
Benefit of the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - petitioner had not filed returns during the relevant period - The stand of the Department is in fact beneficial to the appellant especially since the Department had the option of treating the petitioner's declarations as 'never made', and thereby denying it the benefits under the scheme and initiating proceedings for recovery of the tax amount, together with penalty and interest in accordance with the statutory provisions. - HC
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