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...
Principles of natural justice violated due to lack of proper communication regarding show cause notice and order, leading to tax demand confirmation without petitioner's response. Court set aside the order and remanded matter for reconsideration, subject to petitioner remitting 10% of disputed tax demand within two weeks, acknowledging procedural lapse despite imposing condition. Petition disposed through remand for fresh consideration after partial compliance.
Principles of natural justice violated due to lack of proper communication regarding show cause notice and order, leading to tax demand confirmation without petitioner's response. Court set aside the order and remanded matter for reconsideration, subject to petitioner remitting 10% of disputed tax demand within two weeks, acknowledging procedural lapse despite imposing condition. Petition disposed through remand for fresh consideration after partial compliance.
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