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 SLP challenging rectification of GST returns beyond prescribed timelines. The court held that the right to correct clerical or arithmetical errors is inherent in conducting business and should not be denied without substantial justification. Software limitations cannot be a valid reason to prevent error correction, as technological systems can be reconfigured to facilitate compliance. The ruling emphasizes taxpayers' procedural flexibility in addressing inadvertent mistakes in tax documentation, affirming the principle of substantive justice over rigid procedural constraints.
HC dismissed SLP challenging rectification of GST returns beyond prescribed timelines. The court held that the right to correct clerical or arithmetical errors is inherent in conducting business and should not be denied without substantial justification. Software limitations cannot be a valid reason to prevent error correction, as technological systems can be reconfigured to facilitate compliance. The ruling emphasizes taxpayers' procedural flexibility in addressing inadvertent mistakes in tax documentation, affirming the principle of substantive justice over rigid procedural constraints.
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