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 the appeal, finding no substantial question of law regarding invocation of the extended five-year limitation period under Section 73(1) of Finance Act, 1994. The court upheld CESTAT's determination that the respondent's actions were based on bona fide belief rather than wilful misstatement or fraud. Though the Commissioner issued a composite show cause notice covering 2004-2009, the court declined to interfere with CESTAT's order, particularly regarding the period after the August 23, 2007 master circular, as no fraudulent intent was established to justify extending the limitation period.
HC dismissed the appeal, finding no substantial question of law regarding invocation of the extended five-year limitation period under Section 73(1) of Finance Act, 1994. The court upheld CESTAT's determination that the respondent's actions were based on bona fide belief rather than wilful misstatement or fraud. Though the Commissioner issued a composite show cause notice covering 2004-2009, the court declined to interfere with CESTAT's order, particularly regarding the period after the August 23, 2007 master circular, as no fraudulent intent was established to justify extending the limitation period.
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