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 impugned order dated 31 January 2025 and allowed the petition by way of remand. The court addressed an appeal concerning invocation of the extended period of limitation and prior reversal of input tax credit appropriation, noting the Revenue's failure to produce documentary proof of foreign exchange realization such as BRCs or FIRCs. The HC held that FIRCs need not correspond transaction-by-transaction and may be maintained on a periodic basis, provided the aggregate foreign exchange remitted fully substantiates the claimed benefit. The matter is remitted for fresh consideration in accordance with this principle and applicable law, with liberty to both parties to lead relevant evidence.
The HC set aside the impugned order dated 31 January 2025 and allowed the petition by way of remand. The court addressed an appeal concerning invocation of the extended period of limitation and prior reversal of input tax credit appropriation, noting the Revenue's failure to produce documentary proof of foreign exchange realization such as BRCs or FIRCs. The HC held that FIRCs need not correspond transaction-by-transaction and may be maintained on a periodic basis, provided the aggregate foreign exchange remitted fully substantiates the claimed benefit. The matter is remitted for fresh consideration in accordance with this principle and applicable law, with liberty to both parties to lead relevant evidence.
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