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...
100% EOU - Demand of customs duty on goods that were imported but remained undelivered, by rejecting the request of the appellant for remission of the duty - Nothing was hidden nor is there any attempt to play fraud or suppression of any facts on the part of the appellant insofar as the shortage in supply was concerned, which fact was very much within the knowledge of the Revenue. Thus, there was absolutely no scope for the Revenue to assume jurisdiction by invoking the extended period of limitation since any allegation as to fraud or suppression would only be a whim and arbitrary. - AT
100% EOU - Demand of customs duty on goods that were imported but remained undelivered, by rejecting the request of the appellant for remission of the duty - Nothing was hidden nor is there any attempt to play fraud or suppression of any facts on the part of the appellant insofar as the shortage in supply was concerned, which fact was very much within the knowledge of the Revenue. Thus, there was absolutely no scope for the Revenue to assume jurisdiction by invoking the extended period of limitation since any allegation as to fraud or suppression would only be a whim and arbitrary. - AT
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