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...
Refund claim - rejection on the ground of time limitation - The High Court noted the applicability of the Notification dated 05.07.2022, which explicitly excluded the relevant period for the computation of the limitation period. As the petitioner's case fell within this excluded period, the rejection of the refund applications solely on the ground of limitation was deemed unsustainable. - The HC restored the refund applications to the record of the Assessing Authority.
Refund claim - rejection on the ground of time limitation - The High Court noted the applicability of the Notification dated 05.07.2022, which explicitly excluded the relevant period for the computation of the limitation period. As the petitioner's case fell within this excluded period, the rejection of the refund applications solely on the ground of limitation was deemed unsustainable. - The HC restored the refund applications to the record of the Assessing Authority.
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