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 impugned composite show-cause notices and assessment orders for consolidating multiple tax periods, holding that a single SCN or composite assessment cannot cover more than one tax period (monthly or annual as applicable) and that separate assessments must be framed for each assessment year; divergence in High Courts' precedents noted but statutory interpretation, read with related provisions and the rights to benefits and appeals under the GST framework, requires distinct orders per period. The writ petitions were disposed of, quashing the composite orders and permitting respondents to initiate fresh proceedings confined to each assessment year separately.
The HC set aside impugned composite show-cause notices and assessment orders for consolidating multiple tax periods, holding that a single SCN or composite assessment cannot cover more than one tax period (monthly or annual as applicable) and that separate assessments must be framed for each assessment year; divergence in High Courts' precedents noted but statutory interpretation, read with related provisions and the rights to benefits and appeals under the GST framework, requires distinct orders per period. The writ petitions were disposed of, quashing the composite orders and permitting respondents to initiate fresh proceedings confined to each assessment year separately.
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