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 AT accepted the DGAP report in part, finding that the respondent had profiteered Rs. 6,88,770 for the period 27.07.2018-31.10.2018 and directed the respondent to deposit that profiteered amount into the Consumer Welfare Fund, to be apportioned equally between the Centre and States. The Tribunal held that the statutory provision imposing interest at 18% on profiteered amounts is not applicable retrospectively; it operates only from the date the amending rule came into force (post-28.06.2019), and therefore, because the profiteering occurred prior thereto, the respondent was not directed to pay interest. The application was disposed of accordingly.
The AT accepted the DGAP report in part, finding that the respondent had profiteered Rs. 6,88,770 for the period 27.07.2018-31.10.2018 and directed the respondent to deposit that profiteered amount into the Consumer Welfare Fund, to be apportioned equally between the Centre and States. The Tribunal held that the statutory provision imposing interest at 18% on profiteered amounts is not applicable retrospectively; it operates only from the date the amending rule came into force (post-28.06.2019), and therefore, because the profiteering occurred prior thereto, the respondent was not directed to pay interest. The application was disposed of accordingly.
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