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 Income Tax Appellate Tribunal allowed the assessee's appeal for statistical purposes. It set aside the CIT(A)'s dismissal of the rectification application and directed the CIT(A) to decide the grounds of appeal raised by the assessee on merits as per Section 250(6) of the Act. The Tribunal held that the CIT(A)'s action of not interfering with the CPC's adjustment regarding GST/CENVAT refund on the ground of requiring verification of books of accounts was akin to "missing the woods for trees". The Tribunal emphasized that rules of procedure should promote justice, not obstruct it, relying on the Supreme Court's observation in MV Vali Perov. Fernandeo Lopez case.
The Income Tax Appellate Tribunal allowed the assessee's appeal for statistical purposes. It set aside the CIT(A)'s dismissal of the rectification application and directed the CIT(A) to decide the grounds of appeal raised by the assessee on merits as per Section 250(6) of the Act. The Tribunal held that the CIT(A)'s action of not interfering with the CPC's adjustment regarding GST/CENVAT refund on the ground of requiring verification of books of accounts was akin to "missing the woods for trees". The Tribunal emphasized that rules of procedure should promote justice, not obstruct it, relying on the Supreme Court's observation in MV Vali Perov. Fernandeo Lopez case.
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