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...
Appellate authority failed to consider documentary evidence already placed before the adjudicating authority; accordingly the appellate order is quashed and the matter remanded for fresh hearing requiring consideration of those documents. The petitioner did not appear at the scheduled personal hearings despite service of notices, and the court found absence of fault in the appellate authority's decision to proceed given nonappearance; however the appellate authority was nevertheless obliged to examine the documentary record when adjudicating the appeal, and its failure to do so determined the remand outcome.
Appellate authority failed to consider documentary evidence already placed before the adjudicating authority; accordingly the appellate order is quashed and the matter remanded for fresh hearing requiring consideration of those documents. The petitioner did not appear at the scheduled personal hearings despite service of notices, and the court found absence of fault in the appellate authority's decision to proceed given nonappearance; however the appellate authority was nevertheless obliged to examine the documentary record when adjudicating the appeal, and its failure to do so determined the remand outcome.
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