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...
Levy of Penalty u/r 26 of CER on the buyer / purchaser of goods - The Revenue has not brought on record as to the role of the appellant in the non-payment of Excise Duty by the said manufacturer; the appellant has pleaded that it was only procuring the said AVS and the only relationship that existed was that of manufacturer and purchaser and nothing more than that, which is not disputed by the Revenue. - No penalty - AT
Levy of Penalty u/r 26 of CER on the buyer / purchaser of goods - The Revenue has not brought on record as to the role of the appellant in the non-payment of Excise Duty by the said manufacturer; the appellant has pleaded that it was only procuring the said AVS and the only relationship that existed was that of manufacturer and purchaser and nothing more than that, which is not disputed by the Revenue. - No penalty - AT
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