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...
Tax authority rejected rectification application filed by taxpayer for zero-rated supply citing violation of principles of natural justice. Court examined impugned order, found taxpayer's reply and documents were considered for most defects except two. For those two defects, court set aside impugned order subject to taxpayer remitting 20% of disputed tax demand and re-submitting relevant documents within 15 days. Tax authority directed to provide reasonable opportunity including personal hearing to taxpayer and pass fresh order within 3 months after receiving taxpayer's reply. Petition disposed.
Tax authority rejected rectification application filed by taxpayer for zero-rated supply citing violation of principles of natural justice. Court examined impugned order, found taxpayer's reply and documents were considered for most defects except two. For those two defects, court set aside impugned order subject to taxpayer remitting 20% of disputed tax demand and re-submitting relevant documents within 15 days. Tax authority directed to provide reasonable opportunity including personal hearing to taxpayer and pass fresh order within 3 months after receiving taxpayer's reply. Petition disposed.
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