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...
Dispute centered on whether exemption granted for transmission or distribution of electricity extends to ancillary services offered by utility companies. Court ordered stay on penalty proceedings until Supreme Court delivers judgment on exemption applicability to ancillary services. If ruled against assessee, penalty imposition to be independently evaluated based on governing principles. Petitions disposed, maintaining status quo on payments and penalty proceedings pending Supreme Court's final decision.
Dispute centered on whether exemption granted for transmission or distribution of electricity extends to ancillary services offered by utility companies. Court ordered stay on penalty proceedings until Supreme Court delivers judgment on exemption applicability to ancillary services. If ruled against assessee, penalty imposition to be independently evaluated based on governing principles. Petitions disposed, maintaining status quo on payments and penalty proceedings pending Supreme Court's final decision.
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