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 HC quashed the show cause notice pending adjudication for over 15 years due to inordinate and unexplained delay by the respondent. The respondent's affidavit failed to justify the delay satisfactorily. The SC order cited does not mandate excusing gross, unjustifiable, and inordinate delays in adjudicating show cause notices without reasonable explanation. Consequently, the HC restrained the respondents from further proceedings based on the impugned show cause notice.
The HC quashed the show cause notice pending adjudication for over 15 years due to inordinate and unexplained delay by the respondent. The respondent's affidavit failed to justify the delay satisfactorily. The SC order cited does not mandate excusing gross, unjustifiable, and inordinate delays in adjudicating show cause notices without reasonable explanation. Consequently, the HC restrained the respondents from further proceedings based on the impugned show cause notice.
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