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...
Maintainability of appeal - non deposit of 7.5% of the amount of duty - delay in filing of appeal - observations are opined sufficient to falsify the allegations against the previous counsel that he was negligent and that he was responsible for these delay, as substantial as that of more than two and a half years, for filing the appeal before Commissioner (Appeals). There is not even any affidavit of the said previous counsel on record, acknowledging the alleged negligence on his part. - the appeal is dismissed - AT
Maintainability of appeal - non deposit of 7.5% of the amount of duty - delay in filing of appeal - observations are opined sufficient to falsify the allegations against the previous counsel that he was negligent and that he was responsible for these delay, as substantial as that of more than two and a half years, for filing the appeal before Commissioner (Appeals). There is not even any affidavit of the said previous counsel on record, acknowledging the alleged negligence on his part. - the appeal is dismissed - AT
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