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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...
The interplay between Sections 129 and 130 of the CGST Act was analyzed. Section 129 applies when goods are in transit, while Section 130 allows confiscation and penalty for specific violations. Proceedings u/s 130 without prior Section 129 action were deemed invalid. Non-affixture of DIN on confiscation order and violation of natural justice principles by not providing material relied upon were also discussed. The confiscation orders were set aside, and matters remanded for proper adjudication following natural justice principles.
The interplay between Sections 129 and 130 of the CGST Act was analyzed. Section 129 applies when goods are in transit, while Section 130 allows confiscation and penalty for specific violations. Proceedings u/s 130 without prior Section 129 action were deemed invalid. Non-affixture of DIN on confiscation order and violation of natural justice principles by not providing material relied upon were also discussed. The confiscation orders were set aside, and matters remanded for proper adjudication following natural justice principles.
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