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...
Arbitral Proceedings - Computation of one-year period for completing the proceedings - exclusion of days during which the proceedings were stayed - The High Court acknowledged the stay of proceedings ordered by the Court and held that the period during which the proceedings were stayed should be excluded from the calculation of the one-year period for making the award. They emphasized the principle that periods of stay ordered by courts should be excluded when calculating timelines. The Court reiterated the importance of adhering to the provisions of the Arbitration and Conciliation Act, 1996, to ensure the expeditious resolution of disputes.
Arbitral Proceedings - Computation of one-year period for completing the proceedings - exclusion of days during which the proceedings were stayed - The High Court acknowledged the stay of proceedings ordered by the Court and held that the period during which the proceedings were stayed should be excluded from the calculation of the one-year period for making the award. They emphasized the principle that periods of stay ordered by courts should be excluded when calculating timelines. The Court reiterated the importance of adhering to the provisions of the Arbitration and Conciliation Act, 1996, to ensure the expeditious resolution of disputes.
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