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...
Jurisdiction - power to adjudicate SCN - The High Court rejected the contention that the previous involvement of a Commissioner of Customs in the case's proceedings biased the adjudication process. It held that the competence and authority of the officer who issued the Show Cause Notice were not affected by the Commissioner's involvement. The Court noted the legal provisions empowering certain officers to authorize arrests and issue Show Cause Notices. It also acknowledged a notification specifying procedures for representation before the High Court but concluded that the involvement of a Commissioner of Customs did not affect the authority of the adjudicating officer.
Jurisdiction - power to adjudicate SCN - The High Court rejected the contention that the previous involvement of a Commissioner of Customs in the case's proceedings biased the adjudication process. It held that the competence and authority of the officer who issued the Show Cause Notice were not affected by the Commissioner's involvement. The Court noted the legal provisions empowering certain officers to authorize arrests and issue Show Cause Notices. It also acknowledged a notification specifying procedures for representation before the High Court but concluded that the involvement of a Commissioner of Customs did not affect the authority of the adjudicating officer.
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