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 found detention of vehicle and goods under Section 129 was improper. Physical verification confirmed correct quantity and weight of goods against three invoices, with no discrepancy in broad product classifications. Inspecting authority exceeded scope by scrutinizing detailed specifications (pipe size, shutter, TMT Bar dimensions) not required in invoices. While product classification issues could be addressed in separate adjudication proceedings, current detention was unwarranted as there was no evidence of tax evasion or fact suppression. Court ordered release of vehicle and goods within four days of order service. Matter disposed with directive to authorities to comply with release order.
HC found detention of vehicle and goods under Section 129 was improper. Physical verification confirmed correct quantity and weight of goods against three invoices, with no discrepancy in broad product classifications. Inspecting authority exceeded scope by scrutinizing detailed specifications (pipe size, shutter, TMT Bar dimensions) not required in invoices. While product classification issues could be addressed in separate adjudication proceedings, current detention was unwarranted as there was no evidence of tax evasion or fact suppression. Court ordered release of vehicle and goods within four days of order service. Matter disposed with directive to authorities to comply with release order.
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