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...
Prayer for recalling of Final Order - Most of the documents as annexed with the present application also are with respect to Financial Year 2013-14 and 2014-15. Though balance-sheet as on 31st March, 2013 has also been annexed but the fact remains is that the said document, admittedly, was provided on 12.04.2012, for the first time, whereas the order in hand was dictated and pronounced on 11.04.2022. Had it been provided at the time of dictation also the said statement could have been taken into consideration. Being a document which was never provided before any of the adjudicating authorities below there seems no reason otherwise to take this document on record. - AT
Prayer for recalling of Final Order - Most of the documents as annexed with the present application also are with respect to Financial Year 2013-14 and 2014-15. Though balance-sheet as on 31st March, 2013 has also been annexed but the fact remains is that the said document, admittedly, was provided on 12.04.2012, for the first time, whereas the order in hand was dictated and pronounced on 11.04.2022. Had it been provided at the time of dictation also the said statement could have been taken into consideration. Being a document which was never provided before any of the adjudicating authorities below there seems no reason otherwise to take this document on record. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
