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...
Valuation of imported goods - aluminium scrap - enhancement of value - The Tribunal referred to a previous decision where it was asserted that the appellant had agreed to the enhanced value as determined by the department. However, the appellant vehemently denied giving such consent. Given the serious dispute over consent, the Tribunal decided that this core issue needed resolution before relying on any precedent. Consequently, the Tribunal decided to send the matter back to the Division Bench for a decision on this core issue.
Valuation of imported goods - aluminium scrap - enhancement of value - The Tribunal referred to a previous decision where it was asserted that the appellant had agreed to the enhanced value as determined by the department. However, the appellant vehemently denied giving such consent. Given the serious dispute over consent, the Tribunal decided that this core issue needed resolution before relying on any precedent. Consequently, the Tribunal decided to send the matter back to the Division Bench for a decision on this core issue.
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