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 did not make required pre-deposit for maintaining appeal - appeal initially filed belatedly, defective and rejected without merits - subsequent appeal filed with pre-deposit also belated - no lack of bona fide - petitioners already paid over 11% of disputed tax, more than required for appeal - matter remanded to appellate authority for decision on merits as substantial compliance with pre-deposit.
Petitioners did not make required pre-deposit for maintaining appeal - appeal initially filed belatedly, defective and rejected without merits - subsequent appeal filed with pre-deposit also belated - no lack of bona fide - petitioners already paid over 11% of disputed tax, more than required for appeal - matter remanded to appellate authority for decision on merits as substantial compliance with pre-deposit.
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