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...
Failure to consider statutory GST return forms and portal records was held to be a material legal defect; because the appellate authority did not address figures available in GSTR-1, GSTR-9 and GSTR-3B, its omission constituted an abdication of duty and that appellate order was set aside. The adjudicating authority likewise failed to consider the same return records; that adjudication order was set aside and the matter remanded for fresh merits adjudication, with an express right to hearing. Consequentially, no recovery may proceed on the vacated orders and time exclusion for limitation was recorded.
Failure to consider statutory GST return forms and portal records was held to be a material legal defect; because the appellate authority did not address figures available in GSTR-1, GSTR-9 and GSTR-3B, its omission constituted an abdication of duty and that appellate order was set aside. The adjudicating authority likewise failed to consider the same return records; that adjudication order was set aside and the matter remanded for fresh merits adjudication, with an express right to hearing. Consequentially, no recovery may proceed on the vacated orders and time exclusion for limitation was recorded.
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