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 licence agreement is a binding contract whose express terms require timely payment of licence fee, GST and interest; the petitioner breached those obligations by accruing substantial arrears, and the court treated the GST obligation as a statutory levy not excluded by the contract-consequence: petitioner's confusion on GST rejected. The existence of an in contract dispute resolution/alternative remedy led the court to decline exercise of extraordinary writ jurisdiction under Article 226 and dispose of the writ petition, while permitting the petitioner to pursue remedies provided in the agreement.
The licence agreement is a binding contract whose express terms require timely payment of licence fee, GST and interest; the petitioner breached those obligations by accruing substantial arrears, and the court treated the GST obligation as a statutory levy not excluded by the contract-consequence: petitioner's confusion on GST rejected. The existence of an in contract dispute resolution/alternative remedy led the court to decline exercise of extraordinary writ jurisdiction under Article 226 and dispose of the writ petition, while permitting the petitioner to pursue remedies provided in the agreement.
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