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...
Appeal dismissed due to filing beyond statutory limitation period. Petitioner's registration cancelled earlier, failed to avail amnesty scheme allowing restoration upon clearing dues. Petitioner not registered dealer during intervening period, activities unmonitored, transactions unascertainable. Petitioner did not controvert allegation of non-filing returns for six months. Law favors diligent, not indolent. Delay counted against petitioner. Petition dismissed.
Appeal dismissed due to filing beyond statutory limitation period. Petitioner's registration cancelled earlier, failed to avail amnesty scheme allowing restoration upon clearing dues. Petitioner not registered dealer during intervening period, activities unmonitored, transactions unascertainable. Petitioner did not controvert allegation of non-filing returns for six months. Law favors diligent, not indolent. Delay counted against petitioner. Petition dismissed.
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