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...
Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - it appears that the rejection is by a computer generated and/or a mechanical process by a remark that ‘show cause notice issued after 30th June, 2019’. Certainly there is no application of mind on the petitioner’s application on the provisions as made by clarificatory circular, as no reasons are furnished as to why the petitioner’s declaration cannot be entertained applying clause 2(viii) of the said Circular. - Application resumed - HC
Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - it appears that the rejection is by a computer generated and/or a mechanical process by a remark that ‘show cause notice issued after 30th June, 2019’. Certainly there is no application of mind on the petitioner’s application on the provisions as made by clarificatory circular, as no reasons are furnished as to why the petitioner’s declaration cannot be entertained applying clause 2(viii) of the said Circular. - Application resumed - HC
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