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...
Petitioners sought refund of investment under 'buy-back' clause, but failed to furnish FEMA certificate, delaying release of deposited amount. Despite depositing investment amount per court's directions, petitioners didn't comply with formalities, waiving rights for claim before Official Liquidator. With much time elapsed, deposited amount with accrued interest to be utilized for satisfying secured creditors' claims instead of refund to petitioners. Application dismissed.
Petitioners sought refund of investment under 'buy-back' clause, but failed to furnish FEMA certificate, delaying release of deposited amount. Despite depositing investment amount per court's directions, petitioners didn't comply with formalities, waiving rights for claim before Official Liquidator. With much time elapsed, deposited amount with accrued interest to be utilized for satisfying secured creditors' claims instead of refund to petitioners. Application dismissed.
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