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 writ petition challenging tax refund rejection, holding that the petitioner must first exhaust statutory appellate remedies under Section 107 of CGST Act before seeking judicial intervention. The court found the challenge premature, as the underlying adjudication order comprehensively addressed factual issues. The petitioner was directed to pursue the prescribed administrative appeal mechanism, thereby maintaining procedural propriety and preventing premature judicial interference in tax dispute resolution.
HC dismissed the writ petition challenging tax refund rejection, holding that the petitioner must first exhaust statutory appellate remedies under Section 107 of CGST Act before seeking judicial intervention. The court found the challenge premature, as the underlying adjudication order comprehensively addressed factual issues. The petitioner was directed to pursue the prescribed administrative appeal mechanism, thereby maintaining procedural propriety and preventing premature judicial interference in tax dispute resolution.
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