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...
Validity of assessment order - Disparity in Returns - The High Court examined the case thoroughly. It noted that the entire tax liability stemmed from the disparity between the petitioner's GSTR 3B return and the auto-populated GSTR 2A return. Considering Circular No.183, which required obtaining a certificate from the supplier, the Court acknowledged that the petitioner eventually obtained the certificate, albeit belatedly. - The High Court, considering the submissions and evidence presented, set aside the impugned order and directed the respondent to provide the petitioner with a fair opportunity to address the tax demand.
Validity of assessment order - Disparity in Returns - The High Court examined the case thoroughly. It noted that the entire tax liability stemmed from the disparity between the petitioner's GSTR 3B return and the auto-populated GSTR 2A return. Considering Circular No.183, which required obtaining a certificate from the supplier, the Court acknowledged that the petitioner eventually obtained the certificate, albeit belatedly. - The High Court, considering the submissions and evidence presented, set aside the impugned order and directed the respondent to provide the petitioner with a fair opportunity to address the tax demand.
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