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...
Limitation for issuance of a tax recovery order under Section 73 was considered alongside an extension by notification; because the impugned order was ex parte after the petitioner failed to reply to the show cause notice, the court remitted the matter for fresh adjudication on merits. The respondent must give notice before passing any fresh order. Proceeding will continue only if the petitioner deposits 50% of the disputed tax in cash or from its electronic cash ledger within 30 days; bank attachment will be lifted upon that deposit, and failure to comply permits recovery as if the petition were dismissed.
Limitation for issuance of a tax recovery order under Section 73 was considered alongside an extension by notification; because the impugned order was ex parte after the petitioner failed to reply to the show cause notice, the court remitted the matter for fresh adjudication on merits. The respondent must give notice before passing any fresh order. Proceeding will continue only if the petitioner deposits 50% of the disputed tax in cash or from its electronic cash ledger within 30 days; bank attachment will be lifted upon that deposit, and failure to comply permits recovery as if the petition were dismissed.
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