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...
The HC set aside the cancellation order dated 6th August 2024 and the subsequent appellate order dated 21st March 2025, restoring the petitioner's registration. The court found that while registration was cancelled for non-filing of returns, there was no evidence of dubious tax evasion practices. Emphasizing that suspension would be counterproductive to revenue interests as it prevents business operations and tax recovery, the court adopted a pragmatic approach. The restoration was granted conditionally, requiring the petitioner to file all outstanding returns for the default period and pay requisite taxes, interest, fines, and penalties. The court noted that respondents cannot determine final liability without filed returns, making restoration essential for proper tax administration.
The HC set aside the cancellation order dated 6th August 2024 and the subsequent appellate order dated 21st March 2025, restoring the petitioner's registration. The court found that while registration was cancelled for non-filing of returns, there was no evidence of dubious tax evasion practices. Emphasizing that suspension would be counterproductive to revenue interests as it prevents business operations and tax recovery, the court adopted a pragmatic approach. The restoration was granted conditionally, requiring the petitioner to file all outstanding returns for the default period and pay requisite taxes, interest, fines, and penalties. The court noted that respondents cannot determine final liability without filed returns, making restoration essential for proper tax administration.
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