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...
Extended period of limitation - it is found that appellant were under the bonafide belief that no service tax was payable on the brokerage received by them for providing steamer agent service being a sub-agent - also, all the transactions between the appellant and M/s. Freight Connection India Pvt. Limited are recorded in the books of accounts - extended time to demand service tax under Section 73 is not invokable. - AT
Extended period of limitation - it is found that appellant were under the bonafide belief that no service tax was payable on the brokerage received by them for providing steamer agent service being a sub-agent - also, all the transactions between the appellant and M/s. Freight Connection India Pvt. Limited are recorded in the books of accounts - extended time to demand service tax under Section 73 is not invokable. - AT
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