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...
Declaration of Petitioner as a Wilful Defaulter under the Master Circular on Wilful Defaulters, 2015 - depriving the Petitioner from availing credit facilities for his present and prospective business enterprises - The High court found that the bank's reliance on a Forensic Audit Report, without independent verification or considering the petitioner's track record and the context of transactions, was inadequate to substantiate the declaration. - The court held that the bank failed to establish that the alleged acts of Wilful Default were "intentional, deliberate, and calculated," as required under the RBI's Master Circular.
Declaration of Petitioner as a Wilful Defaulter under the Master Circular on Wilful Defaulters, 2015 - depriving the Petitioner from availing credit facilities for his present and prospective business enterprises - The High court found that the bank's reliance on a Forensic Audit Report, without independent verification or considering the petitioner's track record and the context of transactions, was inadequate to substantiate the declaration. - The court held that the bank failed to establish that the alleged acts of Wilful Default were "intentional, deliberate, and calculated," as required under the RBI's Master Circular.
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