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 dismissed the writ petition challenging three Orders-in-Original concerning demands for allegedly fraudulent availment of ITC, holding that factual determinations on fraudulent ITC cannot be adjudicated in writ jurisdiction and noting precedent from higher courts. The Court found non-entertainment of the writ appropriate and declined to interfere on merits for lack of natural justice issues warranting writ relief. The Petitioner was permitted to challenge each O-O by filing statutory appeals; any amounts already deposited are to be adjusted against pre-deposits in those appeals. Petition disposed of.
The HC dismissed the writ petition challenging three Orders-in-Original concerning demands for allegedly fraudulent availment of ITC, holding that factual determinations on fraudulent ITC cannot be adjudicated in writ jurisdiction and noting precedent from higher courts. The Court found non-entertainment of the writ appropriate and declined to interfere on merits for lack of natural justice issues warranting writ relief. The Petitioner was permitted to challenge each O-O by filing statutory appeals; any amounts already deposited are to be adjusted against pre-deposits in those appeals. Petition disposed of.
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