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...
CENVAT Credit availed on manpower supply and housekeeping services received at unregistered job working units. Credit availed beyond six months from document date. Extended period invoked for demand, interest and penalty. Held: Input service definition construed widely, credit allowed on services consumed in unregistered premises as per jurisdictional High Court. Time limit u/r 4 not retrospective, credit allowed on invoices prior to September 2014 based on Delhi High Court ruling. No evidence of suppression, issues interpretational, extended period invoked incorrectly. Impugned orders set aside, appeal allowed.
CENVAT Credit availed on manpower supply and housekeeping services received at unregistered job working units. Credit availed beyond six months from document date. Extended period invoked for demand, interest and penalty. Held: Input service definition construed widely, credit allowed on services consumed in unregistered premises as per jurisdictional High Court. Time limit u/r 4 not retrospective, credit allowed on invoices prior to September 2014 based on Delhi High Court ruling. No evidence of suppression, issues interpretational, extended period invoked incorrectly. Impugned orders set aside, appeal allowed.
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