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...
Petition maintainability hinges on alternative remedy availability. Excess tax refund due to ignorance and legal ambiguity. Supreme Court ruled that purely legal controversies without factual disputes should be decided by High Court, not dismissed for alternative remedy availability. However, where statute provides grievance redressal mechanism, writ petition should not be entertained. Appellant company did not dispute authority's jurisdiction or lack of CGST Act's redressal mechanism. High Court's discretion in refusing writ petitions due to efficacious alternate remedy was upheld, dismissing appeals.
Petition maintainability hinges on alternative remedy availability. Excess tax refund due to ignorance and legal ambiguity. Supreme Court ruled that purely legal controversies without factual disputes should be decided by High Court, not dismissed for alternative remedy availability. However, where statute provides grievance redressal mechanism, writ petition should not be entertained. Appellant company did not dispute authority's jurisdiction or lack of CGST Act's redressal mechanism. High Court's discretion in refusing writ petitions due to efficacious alternate remedy was upheld, dismissing appeals.
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