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 exemption - Demand beyond the scope of the Show Cause Notice (SCN) - Procurement of GTA service for export - When the return itself requires the details, there is no requirement for the show cause notice to specify in the said details, as has been submitted by the learned counsel for the appellant. - the appellant has complied with the notification condition as enumerated in column 4 of the aforesaid table. In view of the same, the demand of duty and interest is set aside. - AT
Denial of exemption - Demand beyond the scope of the Show Cause Notice (SCN) - Procurement of GTA service for export - When the return itself requires the details, there is no requirement for the show cause notice to specify in the said details, as has been submitted by the learned counsel for the appellant. - the appellant has complied with the notification condition as enumerated in column 4 of the aforesaid table. In view of the same, the demand of duty and interest is set aside. - AT
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