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 quashed the impugned orders rejecting refund claims for unutilized ITC as time-barred, finding that the limitation extension applicable to the statutory window period renders the refund filings within limitation. The petitioner's refund applications are restored to the file of the Proper Officer, who is directed to treat the applications as within limitation and adjudicate them on merits. The Proper Officer must dispose of the restored refund applications in accordance with law expeditiously, and in any event within three months from the date of uploading of this order. The petition is disposed of.
The HC quashed the impugned orders rejecting refund claims for unutilized ITC as time-barred, finding that the limitation extension applicable to the statutory window period renders the refund filings within limitation. The petitioner's refund applications are restored to the file of the Proper Officer, who is directed to treat the applications as within limitation and adjudicate them on merits. The Proper Officer must dispose of the restored refund applications in accordance with law expeditiously, and in any event within three months from the date of uploading of this order. The petition is disposed of.
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