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 court addressed whether parallel proceedings under Sections 73/74 and Section 122 (penalty) create impermissible overlap and whether the show-cause notice could proceed pending resolution of a state appeal; it declined to decide the overlap on merits but ordered the state Appellate Authority to conclude the pending appeal within a limited period - outcome: appeal to be disposed within three weeks and the Central Authorities may proceed with the show-cause notice only after that conclusion. The petitioner may thereafter file a reply raising the overlap and reliance on the CBIC circular; remedies preserved. - HC
The court addressed whether parallel proceedings under Sections 73/74 and Section 122 (penalty) create impermissible overlap and whether the show-cause notice could proceed pending resolution of a state appeal; it declined to decide the overlap on merits but ordered the state Appellate Authority to conclude the pending appeal within a limited period - outcome: appeal to be disposed within three weeks and the Central Authorities may proceed with the show-cause notice only after that conclusion. The petitioner may thereafter file a reply raising the overlap and reliance on the CBIC circular; remedies preserved. - HC
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