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 invalidated an ex parte service tax assessment order due to procedural irregularities. The court found that the order-in-original was passed five years after the show cause notice, significantly exceeding the prescribed statutory time limits under Section 73(4B) of the Finance Act. Despite Section 73(4B) not mandating a strict time frame, the court held that prolonged delays without substantive justification render the assessment and accompanying penalties void. The petitioner's challenge was upheld, with the impugned order set aside, emphasizing the importance of adhering to reasonable adjudication timelines in tax proceedings.
HC invalidated an ex parte service tax assessment order due to procedural irregularities. The court found that the order-in-original was passed five years after the show cause notice, significantly exceeding the prescribed statutory time limits under Section 73(4B) of the Finance Act. Despite Section 73(4B) not mandating a strict time frame, the court held that prolonged delays without substantive justification render the assessment and accompanying penalties void. The petitioner's challenge was upheld, with the impugned order set aside, emphasizing the importance of adhering to reasonable adjudication timelines in tax proceedings.
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