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...
HC quashed the order and restored the adjudication of show cause notice to the respondent authority. Petitioner is entitled to relief. Adjudicating authority's findings on ownership of goods were contradictory. It failed to properly consider the effect of notification treating amounts obtained through KIIFB as grant from government. Respondent directed to pass fresh order after hearing petitioner, considering whether absence of consideration precludes 'supply' u/s 7 of CGST Act, and whether KIIFB amounts should be treated as government grant under the notification.
HC quashed the order and restored the adjudication of show cause notice to the respondent authority. Petitioner is entitled to relief. Adjudicating authority's findings on ownership of goods were contradictory. It failed to properly consider the effect of notification treating amounts obtained through KIIFB as grant from government. Respondent directed to pass fresh order after hearing petitioner, considering whether absence of consideration precludes 'supply' u/s 7 of CGST Act, and whether KIIFB amounts should be treated as government grant under the notification.
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