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...
Denial of the benefit of the Sabka Vishwas Legacy Dispute Resolution Scheme, 2019 (SVLDR Scheme) - there is no question of the Petitioner’s product being outside the purview of the SVLDR Scheme read with the Fourth Schedule to the CE Act. The Court, therefore, rejects the plea of the Department that the Petitioner would be ineligible for the benefit of the SVLDR Scheme. - HC
Denial of the benefit of the Sabka Vishwas Legacy Dispute Resolution Scheme, 2019 (SVLDR Scheme) - there is no question of the Petitioner’s product being outside the purview of the SVLDR Scheme read with the Fourth Schedule to the CE Act. The Court, therefore, rejects the plea of the Department that the Petitioner would be ineligible for the benefit of the SVLDR Scheme. - HC
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