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 allowed the petitions, holding the appeals were instituted within the extended limitation and therefore not time-barred. The court set aside the impugned orders and restored the petitioners' appeals to the appellate authority for fresh adjudication on merits in accordance with law. The HC relied on a comparable Division Bench decision of Patna HC which observed that the notification relied upon predated the purported cut-off, undermining any rationale for denying filing on the ground of limitation. Consequently, the petitions were allowed and the matter remitted for reconsideration by the appellate authority.
The HC allowed the petitions, holding the appeals were instituted within the extended limitation and therefore not time-barred. The court set aside the impugned orders and restored the petitioners' appeals to the appellate authority for fresh adjudication on merits in accordance with law. The HC relied on a comparable Division Bench decision of Patna HC which observed that the notification relied upon predated the purported cut-off, undermining any rationale for denying filing on the ground of limitation. Consequently, the petitions were allowed and the matter remitted for reconsideration by the appellate authority.
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