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...
The High Court held that the Show Cause Notice (SCN) demanding Integrated Goods and Services Tax (IGST) on the activity of holding equity capital by the Holding Companies in the Petitioner company and on the External Commercial Borrowing (ECB) received by the Petitioner from AOSH was not properly considered. The court quashed the SCN insofar as it relates to the proposal to levy/demand GST on 'Continuous Equity Share holding' and remitted the matter back to the respondent for reconsideration after providing an opportunity to the petitioner regarding the issue of 'Value of the Credit Grant in Service determined as a service fee @1%'. The petitioner was granted liberty to submit its response on this issue within four weeks.
The High Court held that the Show Cause Notice (SCN) demanding Integrated Goods and Services Tax (IGST) on the activity of holding equity capital by the Holding Companies in the Petitioner company and on the External Commercial Borrowing (ECB) received by the Petitioner from AOSH was not properly considered. The court quashed the SCN insofar as it relates to the proposal to levy/demand GST on 'Continuous Equity Share holding' and remitted the matter back to the respondent for reconsideration after providing an opportunity to the petitioner regarding the issue of 'Value of the Credit Grant in Service determined as a service fee @1%'. The petitioner was granted liberty to submit its response on this issue within four weeks.
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