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 dismissed petitions challenging territorial jurisdiction of Additional Commissioner, Kanpur to adjudicate show cause notices (SCNs) issued by DGGI Ahmedabad under CGST Act. Petitioners contested jurisdiction based on Circular 169/2022 and Notification 2/2022, arguing Additional Commissioner lacked All-India jurisdiction. Court held that as per Notification 31/2018, Additional/Joint Commissioner has authority to determine tax liability for SCNs issued by DGGI. Court directed petitioners to raise jurisdictional and other contentions during adjudication proceedings, declining to exercise extraordinary writ jurisdiction under Article 226 at this preliminary stage.
HC dismissed petitions challenging territorial jurisdiction of Additional Commissioner, Kanpur to adjudicate show cause notices (SCNs) issued by DGGI Ahmedabad under CGST Act. Petitioners contested jurisdiction based on Circular 169/2022 and Notification 2/2022, arguing Additional Commissioner lacked All-India jurisdiction. Court held that as per Notification 31/2018, Additional/Joint Commissioner has authority to determine tax liability for SCNs issued by DGGI. Court directed petitioners to raise jurisdictional and other contentions during adjudication proceedings, declining to exercise extraordinary writ jurisdiction under Article 226 at this preliminary stage.
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