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...
Guidelines clarify recovery proceedings in cases where first appeal is disposed but taxpayer cannot file further appeal due to non-operation of Appellate Tribunal. Taxpayers can make pre-deposit payment through Electronic Liability Register to avail stay on recovery. Undertaking to file appeal when Tribunal operationalizes is required. Amounts paid inadvertently through DRC-03 can be adjusted towards pre-deposit by filing DRC-03A application. Till DRC-03A functionality is available, intimation to proper officer suffices for stay on recovery. Failure to file appeal after Tribunal's operation will lead to recovery as per law.
Guidelines clarify recovery proceedings in cases where first appeal is disposed but taxpayer cannot file further appeal due to non-operation of Appellate Tribunal. Taxpayers can make pre-deposit payment through Electronic Liability Register to avail stay on recovery. Undertaking to file appeal when Tribunal operationalizes is required. Amounts paid inadvertently through DRC-03 can be adjusted towards pre-deposit by filing DRC-03A application. Till DRC-03A functionality is available, intimation to proper officer suffices for stay on recovery. Failure to file appeal after Tribunal's operation will lead to recovery as per law.
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