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...
Refund claim - unjust enrichment - value of the software is includable in the assessable value of hardware or not - The duty and the value are shown in the face of Invoice - In addition to these, no other record or evidence has been produced by the appellants. To substantiate their claim of not passing on the incidence of duty - The invoice issued under statutory provisions does not indicate that the incidence of duty has not been passed on. - Refund not allowed - AT
Refund claim - unjust enrichment - value of the software is includable in the assessable value of hardware or not - The duty and the value are shown in the face of Invoice - In addition to these, no other record or evidence has been produced by the appellants. To substantiate their claim of not passing on the incidence of duty - The invoice issued under statutory provisions does not indicate that the incidence of duty has not been passed on. - Refund not allowed - AT
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