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 HC allowed the writ petition, quashed the appellate order, finding merit in the petitioner's case due to procedural irregularities and arbitrary actions by respondent authorities regarding freezing of bank account and subsequent adjudication proceedings. The HC held that statutory limitation provisions should be interpreted liberally where undue hardship is demonstrated, as per precedents, allowing extension of appeal filing period beyond the prescribed 60 days.
The HC allowed the writ petition, quashed the appellate order, finding merit in the petitioner's case due to procedural irregularities and arbitrary actions by respondent authorities regarding freezing of bank account and subsequent adjudication proceedings. The HC held that statutory limitation provisions should be interpreted liberally where undue hardship is demonstrated, as per precedents, allowing extension of appeal filing period beyond the prescribed 60 days.
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