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 applicant had suppressed material facts from the Authority for Advance Ruling by mis-declaring that the issue was not pending in any other proceedings, when in fact, proceedings on the same issue had already commenced by the DGGI. Upon being informed of this by the Appellant, the Authority for Advance Ruling declared the Ruling void ab initio u/s 104 of the Act. Consequently, the appeal filed by the Appellant before the Appellate Authority for Advance Ruling against the void Ruling became infructuous and was dismissed.
The applicant had suppressed material facts from the Authority for Advance Ruling by mis-declaring that the issue was not pending in any other proceedings, when in fact, proceedings on the same issue had already commenced by the DGGI. Upon being informed of this by the Appellant, the Authority for Advance Ruling declared the Ruling void ab initio u/s 104 of the Act. Consequently, the appeal filed by the Appellant before the Appellate Authority for Advance Ruling against the void Ruling became infructuous and was dismissed.
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