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...
Invocation of extraordinary writ jurisdiction - petitioner not entitled to exclusion of time taken in writ proceedings from limitation period for filing appeal. Abuse of process of Court - reagitating issue already decided amounts to abuse, relitigation contrary to justice and public policy. Writ petition dismissed as petitioner cannot seek condonation of delay in filing appeal after writ proceedings set aside assessment order, filing appeal to avoid compliance with writ Court's directions is abuse of process.
Invocation of extraordinary writ jurisdiction - petitioner not entitled to exclusion of time taken in writ proceedings from limitation period for filing appeal. Abuse of process of Court - reagitating issue already decided amounts to abuse, relitigation contrary to justice and public policy. Writ petition dismissed as petitioner cannot seek condonation of delay in filing appeal after writ proceedings set aside assessment order, filing appeal to avoid compliance with writ Court's directions is abuse of process.
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