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...
Oppression and Mismanagement - The Appellate Tribunal highlighted the absence of reasoning in the impugned order, especially regarding the direction for an independent forensic audit. It emphasized the necessity of recording reasons to support judicial orders, citing legal precedents. Despite oral submissions, the Appellant failed to file a reply affidavit or supporting documents, leaving the interim order based solely on the petitioner's averments. The Tribunal upheld the interim order for a forensic audit, considering allegations of serious lapses and non-compliance in financial statements and statutory compliances.
Oppression and Mismanagement - The Appellate Tribunal highlighted the absence of reasoning in the impugned order, especially regarding the direction for an independent forensic audit. It emphasized the necessity of recording reasons to support judicial orders, citing legal precedents. Despite oral submissions, the Appellant failed to file a reply affidavit or supporting documents, leaving the interim order based solely on the petitioner's averments. The Tribunal upheld the interim order for a forensic audit, considering allegations of serious lapses and non-compliance in financial statements and statutory compliances.
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