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...
Petitioner challenged appellate orders rejecting refund applications. HC held there are no grounds to invoke extraordinary jurisdiction under Article 226 as statutory appeal lies before Tribunal. Though Tribunal is not constituted, Central Government permitted filing appeal after its constitution. Since impugned orders relate to refund with no demand, pre-deposit of 20% tax demand is not required. Petition closed.
Petitioner challenged appellate orders rejecting refund applications. HC held there are no grounds to invoke extraordinary jurisdiction under Article 226 as statutory appeal lies before Tribunal. Though Tribunal is not constituted, Central Government permitted filing appeal after its constitution. Since impugned orders relate to refund with no demand, pre-deposit of 20% tax demand is not required. Petition closed.
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