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...
Invocation of extended period of limitation. - The Appellant had been providing same services as was alleged in the earlier Show Cause Notice dated 22.05.2015 which was adjudicated in favour of the Appellant for the earlier period. It is not the case of the Department that there was any change in the nature of services provided by the Appellant and thus when the first Show Cause Notice was issued invoking extended period of limitation, it cannot be alleged that the Appellant has suppressed facts while issuing demand notices for subsequent period. - Demand set aside - AT
Invocation of extended period of limitation. - The Appellant had been providing same services as was alleged in the earlier Show Cause Notice dated 22.05.2015 which was adjudicated in favour of the Appellant for the earlier period. It is not the case of the Department that there was any change in the nature of services provided by the Appellant and thus when the first Show Cause Notice was issued invoking extended period of limitation, it cannot be alleged that the Appellant has suppressed facts while issuing demand notices for subsequent period. - Demand set aside - AT
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