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...
SVLDRS - Recovery of arrears of tax in terms of Section 124(1)(c) of the Sabka Vishwas (Legacy Dispute Resolution Scheme Rules, 2019 in the Finance Act, 2019 - jurisdiction under Section 74 of the Finance Act, 1994 was invoked to rectify the mistake - The High court found that initiating a rectification proceeding under Section 74 cannot be equated with filing an appeal under Section 86 of the Finance Act, 1994. Therefore, the petitioner’s case could not be considered under the appeal category for SVLDRS relief, which necessitates a different calculation of the dues. - The court allowed the settlement under SVLDRS upon payment of the due amount and interest.
SVLDRS - Recovery of arrears of tax in terms of Section 124(1)(c) of the Sabka Vishwas (Legacy Dispute Resolution Scheme Rules, 2019 in the Finance Act, 2019 - jurisdiction under Section 74 of the Finance Act, 1994 was invoked to rectify the mistake - The High court found that initiating a rectification proceeding under Section 74 cannot be equated with filing an appeal under Section 86 of the Finance Act, 1994. Therefore, the petitioner’s case could not be considered under the appeal category for SVLDRS relief, which necessitates a different calculation of the dues. - The court allowed the settlement under SVLDRS upon payment of the due amount and interest.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4796
Join Channel
TaxTMI 
