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...
Adjudication of show cause notice (SCN) after several year - The tribunal noted the history of duty exemption, litigation, and subsequent duty imposition on resin extraction. It highlighted the stay on duty payment due to court orders, the challenge to the duty imposition, and the subsequent liability post-2019 judgment. - The tribunal found that the show cause notices issued during the litigation period were unsustainable, given the stay on duty payment and subsequent release of duty amounts to buyers. It also criticized the delayed adjudication, citing legal precedents for setting aside belated orders and unreasonable delays.
Adjudication of show cause notice (SCN) after several year - The tribunal noted the history of duty exemption, litigation, and subsequent duty imposition on resin extraction. It highlighted the stay on duty payment due to court orders, the challenge to the duty imposition, and the subsequent liability post-2019 judgment. - The tribunal found that the show cause notices issued during the litigation period were unsustainable, given the stay on duty payment and subsequent release of duty amounts to buyers. It also criticized the delayed adjudication, citing legal precedents for setting aside belated orders and unreasonable delays.
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