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 Adjudicating Authority must reconsider the GST assessment by applying Circular No. 199/11/2023-GST and recent precedent. The court found the original order did not properly consider the circular's provisions regarding cross-charged expenses. The Adjudicating Authority is directed to provide a fresh hearing to the petitioner and issue a new order consistent with the circular's guidelines, potentially nullifying the tax liability. The court referenced the Metal One Corporation judgment, which suggested no tax liability where no invoices were generated. Petition disposed of with directions for re-evaluation.
HC held that the Adjudicating Authority must reconsider the GST assessment by applying Circular No. 199/11/2023-GST and recent precedent. The court found the original order did not properly consider the circular's provisions regarding cross-charged expenses. The Adjudicating Authority is directed to provide a fresh hearing to the petitioner and issue a new order consistent with the circular's guidelines, potentially nullifying the tax liability. The court referenced the Metal One Corporation judgment, which suggested no tax liability where no invoices were generated. Petition disposed of with directions for re-evaluation.
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