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 dismissed the writ challenging a suo motu revision order by an Additional Commissioner under s.23(4)(a) of the OST Act, holding the Additional Commissioner validly exercised delegated revisionary power and that the Commissioner lacked jurisdiction to re-initiate revision once such delegated power was exercised. By virtue of the non-obstante clause in s.23(4)(d) and the delegation scheme under s.3/Rule 3, any remedy lies by way of appeal to the Commissioner under s.23(4)(c)(ii). The petitioner was directed to pursue the statutory appellate remedy against the order dated 31 May 2025 before the Commissioner and may raise all available grounds; the writ petition was disposed.
The HC dismissed the writ challenging a suo motu revision order by an Additional Commissioner under s.23(4)(a) of the OST Act, holding the Additional Commissioner validly exercised delegated revisionary power and that the Commissioner lacked jurisdiction to re-initiate revision once such delegated power was exercised. By virtue of the non-obstante clause in s.23(4)(d) and the delegation scheme under s.3/Rule 3, any remedy lies by way of appeal to the Commissioner under s.23(4)(c)(ii). The petitioner was directed to pursue the statutory appellate remedy against the order dated 31 May 2025 before the Commissioner and may raise all available grounds; the writ petition was disposed.
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