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 examined a challenge to an adjudication order allegedly issued without providing hearing opportunity. Despite claims of natural justice violation, the court found extensive documentation requiring detailed factual analysis. Determining this was not an exceptional case warranting bypass of statutory appeal mechanisms, HC dismissed the appeal. However, court granted appellant 30 days from judgment receipt to file statutory appeal, directing appellate authority to accept it without limitation period restrictions. Court emphasized need for thorough factual adjudication through proper appellate channels rather than direct judicial intervention.
HC examined a challenge to an adjudication order allegedly issued without providing hearing opportunity. Despite claims of natural justice violation, the court found extensive documentation requiring detailed factual analysis. Determining this was not an exceptional case warranting bypass of statutory appeal mechanisms, HC dismissed the appeal. However, court granted appellant 30 days from judgment receipt to file statutory appeal, directing appellate authority to accept it without limitation period restrictions. Court emphasized need for thorough factual adjudication through proper appellate channels rather than direct judicial intervention.
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