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 re-imposition of previously dropped demands relating to sub-contracting services and mobilisation advances, holding that those demands had been abandoned in earlier orders and were not before the appellate tribunal on remand; consequently they could not be resurrected without fresh adjudication or express direction. The court found a prima facie entitlement for the Petitioner to challenge only the matters remitted to the CESTAT and therefore permitted the Petitioner to pursue its appellate remedy before CESTAT subject to the conditions imposed by the HC. The petition is disposed, with adjudication on liability to be determined by CESTAT in accordance with the court's observations.
The HC set aside the re-imposition of previously dropped demands relating to sub-contracting services and mobilisation advances, holding that those demands had been abandoned in earlier orders and were not before the appellate tribunal on remand; consequently they could not be resurrected without fresh adjudication or express direction. The court found a prima facie entitlement for the Petitioner to challenge only the matters remitted to the CESTAT and therefore permitted the Petitioner to pursue its appellate remedy before CESTAT subject to the conditions imposed by the HC. The petition is disposed, with adjudication on liability to be determined by CESTAT in accordance with the court's observations.
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