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 of Out-of-turn disposal of appeal due to indefinite deferment of proceedings - Piecemeal adjudication - The appellant sought urgent disposal of the appeal, arguing that the delay was jeopardizing their interests, while the respondent argued that the delay was not detrimental as liability was yet to be determined. The Tribunal ruled in favor of the appellant, directing the adjudicating authority to dispose of the notice within four weeks, considering the impending liquidation of the appellant-company and the limited scope of the stay order issued by the Bombay High Court.
Prayer of Out-of-turn disposal of appeal due to indefinite deferment of proceedings - Piecemeal adjudication - The appellant sought urgent disposal of the appeal, arguing that the delay was jeopardizing their interests, while the respondent argued that the delay was not detrimental as liability was yet to be determined. The Tribunal ruled in favor of the appellant, directing the adjudicating authority to dispose of the notice within four weeks, considering the impending liquidation of the appellant-company and the limited scope of the stay order issued by the Bombay High Court.
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