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...
Rejection of a refund claim was challenged on the ground that necessary supporting documents had not been furnished earlier and a further opportunity was sought to produce additional documents. Applying a justice-oriented approach and principles of fair opportunity, the impugned orders rejecting the refund were set aside and the matter was remitted to the adjudicating authority for fresh reconsideration in accordance with law after granting one more opportunity to file the requisite documents; the petition was allowed by way of remand. - HC
Rejection of a refund claim was challenged on the ground that necessary supporting documents had not been furnished earlier and a further opportunity was sought to produce additional documents. Applying a justice-oriented approach and principles of fair opportunity, the impugned orders rejecting the refund were set aside and the matter was remitted to the adjudicating authority for fresh reconsideration in accordance with law after granting one more opportunity to file the requisite documents; the petition was allowed by way of remand. - HC
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