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...
Export of services - Procedural lapse in submitting the proof of documents - Non-fulfilment of conditions prescribed in the N/N. 18/2009-ST - After hearing both sides, the Tribunal observed that the sole ground for confirming the demand was the non-fulfillment of conditions specified in the Notification. However, considering the explanations provided and the subsequent submission of documents by the appellant, the Court concluded that denial of exemption due to procedural lapses was unjustified.
Export of services - Procedural lapse in submitting the proof of documents - Non-fulfilment of conditions prescribed in the N/N. 18/2009-ST - After hearing both sides, the Tribunal observed that the sole ground for confirming the demand was the non-fulfillment of conditions specified in the Notification. However, considering the explanations provided and the subsequent submission of documents by the appellant, the Court concluded that denial of exemption due to procedural lapses was unjustified.
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