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...
Estimation of exempted turnover and taxable turnover - SAIL was unable to produce materials to show to what extent the canteen sales included sale of tax-free goods and first point tax paid goods - In the absence of SAIL producing records relevant to the issue, even in this Court, the estimation that 70% of the sales was of cooked food items and 30% of tea, coffee and snacks etc. cannot be said to be arbitrary. - HC
Estimation of exempted turnover and taxable turnover - SAIL was unable to produce materials to show to what extent the canteen sales included sale of tax-free goods and first point tax paid goods - In the absence of SAIL producing records relevant to the issue, even in this Court, the estimation that 70% of the sales was of cooked food items and 30% of tea, coffee and snacks etc. cannot be said to be arbitrary. - HC
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