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...
Rejection of petitioner’s application for amendment of the registration, namely, change in address of the petitioner - The court addressed the suspension of the petitioner's registration and the issuance of a show cause notice for cancellation. It noted that these actions were premature and arbitrary since they were based on issues that were subject to the pending amendment application. The court directed the respondent to decide on the pending application within a specified timeframe and allowed the petitioner to file a reply to the show cause notice, reserving their right to challenge any adverse decisions.
Rejection of petitioner’s application for amendment of the registration, namely, change in address of the petitioner - The court addressed the suspension of the petitioner's registration and the issuance of a show cause notice for cancellation. It noted that these actions were premature and arbitrary since they were based on issues that were subject to the pending amendment application. The court directed the respondent to decide on the pending application within a specified timeframe and allowed the petitioner to file a reply to the show cause notice, reserving their right to challenge any adverse decisions.
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