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...
Demand regarding disparity between e-way bills and GSTR 3B returns for 2018-19 to 2020-21 assessment periods. Petitioner stated disparity due to non-taxable supplies in e-way bills portal. Supporting documents not annexed to reply. Respondent did not refer to ITC-04 returns. Petitioner could have provided comprehensive explanation. Order set aside on condition of remitting Rs. 3,50,00,000/- towards disputed tax demand within six weeks and permitted to submit reply with relevant documents. Petition disposed of.
Demand regarding disparity between e-way bills and GSTR 3B returns for 2018-19 to 2020-21 assessment periods. Petitioner stated disparity due to non-taxable supplies in e-way bills portal. Supporting documents not annexed to reply. Respondent did not refer to ITC-04 returns. Petitioner could have provided comprehensive explanation. Order set aside on condition of remitting Rs. 3,50,00,000/- towards disputed tax demand within six weeks and permitted to submit reply with relevant documents. Petition disposed of.
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