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 extraordinary writ relief was maintainable where an alternate statutory remedy with a pre-deposit exists and whether the impugned order was time-barred or tainted by denial of natural justice; factual mixed-questions (service, exemption status, limitation) required adjudication and did not justify bypassing the statutory remedy. The statutory pre-deposit requirement was held not to render the remedy inefficacious. Consequently the writ was declined; petitioner directed to file the prescribed statutory appeal within six weeks after complying with pre-conditions including pre-deposit, and the appellate authority must decide the appeal on merits without disputing limitation. - HC
The court addressed whether extraordinary writ relief was maintainable where an alternate statutory remedy with a pre-deposit exists and whether the impugned order was time-barred or tainted by denial of natural justice; factual mixed-questions (service, exemption status, limitation) required adjudication and did not justify bypassing the statutory remedy. The statutory pre-deposit requirement was held not to render the remedy inefficacious. Consequently the writ was declined; petitioner directed to file the prescribed statutory appeal within six weeks after complying with pre-conditions including pre-deposit, and the appellate authority must decide the appeal on merits without disputing limitation. - HC
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