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...
Advance Ruling application maintainable for recipient liable to pay tax on reverse charge basis, despite definition of 'advance ruling' - Section 95 to be interpreted contextually - Fiction u/s 9(3) brings recipient within ambit of Chapter XVII for seeking Advance Ruling - Application erroneously rejected at threshold u/s 98(2) - No appeal lies against rejection u/s 98(2) - Matter remitted to AAR to decide application afresh u/s 98(4) - Impugned order set aside - Petition allowed by way of remand.
Advance Ruling application maintainable for recipient liable to pay tax on reverse charge basis, despite definition of 'advance ruling' - Section 95 to be interpreted contextually - Fiction u/s 9(3) brings recipient within ambit of Chapter XVII for seeking Advance Ruling - Application erroneously rejected at threshold u/s 98(2) - No appeal lies against rejection u/s 98(2) - Matter remitted to AAR to decide application afresh u/s 98(4) - Impugned order set aside - Petition allowed by way of remand.
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