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 AT allowed the appeal and set aside the impugned order, finding that the Respondent unlawfully retained seized property/documents beyond the initial 180-day period under s.8(3)(a) and failed to furnish relied-upon documents (including FIR copies, ITRs and GSTRs) to the Appellant, thereby breaching procedural fairness; disclosure of the ECIR was correctly deemed unnecessary. The Directorate lacked mandate to continue retention absent proper compliance. If a prosecution complaint has since been filed and the seized property is proposed for confiscation, its release is now governed by the order of the Special Court, and the Appellant remains at liberty to pursue available remedies before that court.
The AT allowed the appeal and set aside the impugned order, finding that the Respondent unlawfully retained seized property/documents beyond the initial 180-day period under s.8(3)(a) and failed to furnish relied-upon documents (including FIR copies, ITRs and GSTRs) to the Appellant, thereby breaching procedural fairness; disclosure of the ECIR was correctly deemed unnecessary. The Directorate lacked mandate to continue retention absent proper compliance. If a prosecution complaint has since been filed and the seized property is proposed for confiscation, its release is now governed by the order of the Special Court, and the Appellant remains at liberty to pursue available remedies before that court.
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