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...
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
Non-issuance of ASMT-10 notice vitiated scrutiny conclusions but not adjudication as petitioner was provided opportunity to show cause - Tax proposal confirmed due to petitioner's failure to reply - Petitioner asserted unawareness of proceedings - Interest of justice warrants opportunity to contest tax demand on merits - Impugned assessment order set aside on condition of remitting 10% of disputed tax demand within 15 days and permitting petitioner to submit reply to show cause notice - Matter remanded for reconsideration in one case.
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