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...
Prayer for a direction extending the validity period of Duty Credit Certificate by a period of 15 years - permit use of the Duty Credit Certificate to defray I.G.S.T and G.S.T Compensation Cess - The High Court held that, the notifications and handbook provisions were within the legal authority and did not violate the petitioner's constitutional rights. - The court acknowledged the petitioner's entitlement under the TPS but noted the procedural and legal complexities that affected the utilization of duty credits. It highlighted that the entitlements were subject to the conditions and limitations set forth in the relevant notifications and handbook provisions. - Thus, the Court cannot come to the aid of the petitioner by granting the relief of extending time by 15 years as the same is not based on any concomitant right.
Prayer for a direction extending the validity period of Duty Credit Certificate by a period of 15 years - permit use of the Duty Credit Certificate to defray I.G.S.T and G.S.T Compensation Cess - The High Court held that, the notifications and handbook provisions were within the legal authority and did not violate the petitioner's constitutional rights. - The court acknowledged the petitioner's entitlement under the TPS but noted the procedural and legal complexities that affected the utilization of duty credits. It highlighted that the entitlements were subject to the conditions and limitations set forth in the relevant notifications and handbook provisions. - Thus, the Court cannot come to the aid of the petitioner by granting the relief of extending time by 15 years as the same is not based on any concomitant right.
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