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...
Cancellation of petitioner's registration due to alleged fraud, willful misstatement, or suppression of facts in obtaining registration. Proper Officer issued show cause notice, but petitioner claimed non-disclosure of basis. Proper Officer clarified and provided documents. Petitioner filed response, but Proper Officer canceled registration on premise of non-reply. Matter remanded to Proper Officer for reconsideration of petitioner's case, taking note of response and affording opportunity of hearing. Petition disposed by way of remand.
Cancellation of petitioner's registration due to alleged fraud, willful misstatement, or suppression of facts in obtaining registration. Proper Officer issued show cause notice, but petitioner claimed non-disclosure of basis. Proper Officer clarified and provided documents. Petitioner filed response, but Proper Officer canceled registration on premise of non-reply. Matter remanded to Proper Officer for reconsideration of petitioner's case, taking note of response and affording opportunity of hearing. Petition disposed by way of remand.
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