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 allowed petition challenging service tax penalties under CGST Act. Penalties pertained to period before CGST implementation when services were exempt under Finance Act 1994. Court relied on precedent from Kanak Automobiles case where tax amount was Rs. 86 lakh compared to present case's Rs. 6,33,879. Distinguishing quantum while following ratio from SC judgment, court found penalties inapplicable since services were exempt during relevant period and CGST provisions could not be applied retrospectively.
HC allowed petition challenging service tax penalties under CGST Act. Penalties pertained to period before CGST implementation when services were exempt under Finance Act 1994. Court relied on precedent from Kanak Automobiles case where tax amount was Rs. 86 lakh compared to present case's Rs. 6,33,879. Distinguishing quantum while following ratio from SC judgment, court found penalties inapplicable since services were exempt during relevant period and CGST provisions could not be applied retrospectively.
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