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 of Excess Customs Duty paid - principles of unjust enrichment - Following proceedings before the Settlement Commission, it was determined that the appellant had indeed overpaid, resulting in an excess amount of refund. The Tribunal upheld the appellant's right to claim the refund, considering the terms of the agreement with their overseas supplier, the treatment of the amount in their accounting records, and legal precedents supporting their case. - The Tribunal concluded that the appellant was entitled to the refund of the excess amount, as they had not passed on the duty burden and had treated it as receivable in their accounts.
Refund of Excess Customs Duty paid - principles of unjust enrichment - Following proceedings before the Settlement Commission, it was determined that the appellant had indeed overpaid, resulting in an excess amount of refund. The Tribunal upheld the appellant's right to claim the refund, considering the terms of the agreement with their overseas supplier, the treatment of the amount in their accounting records, and legal precedents supporting their case. - The Tribunal concluded that the appellant was entitled to the refund of the excess amount, as they had not passed on the duty burden and had treated it as receivable in their accounts.
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