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 held that the trust's registration under SS12A is undisputed, and despite loss of original SS12AA certificate in 2012, respondent authorities must reconstruct their file and reissue the registration certificate. The court directed respondent to complete certificate reconstruction within 12 weeks, enabling the petitioner to claim tax exemptions under SS11 and SS12 without procedural impediments. The petition was disposed of, mandating administrative compliance to restore the trust's legal documentation and tax benefits.
HC held that the trust's registration under SS12A is undisputed, and despite loss of original SS12AA certificate in 2012, respondent authorities must reconstruct their file and reissue the registration certificate. The court directed respondent to complete certificate reconstruction within 12 weeks, enabling the petitioner to claim tax exemptions under SS11 and SS12 without procedural impediments. The petition was disposed of, mandating administrative compliance to restore the trust's legal documentation and tax benefits.
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