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...
Issue estoppel applies in criminal proceedings where an earlier adjudication has distinctly raised or found the same issue, and parties are precluded from advancing legally inconsistent allegations; the court applied this principle to dismiss as barred a later complaint founded on the same letters and facts as an earlier complaint that was finally decided on merits as non-maintainable under company law. The earlier dismissal on merits operated as an estoppel against relitigation, and the subsequent complaint and related orders were quashed with the petition disposed of.
Issue estoppel applies in criminal proceedings where an earlier adjudication has distinctly raised or found the same issue, and parties are precluded from advancing legally inconsistent allegations; the court applied this principle to dismiss as barred a later complaint founded on the same letters and facts as an earlier complaint that was finally decided on merits as non-maintainable under company law. The earlier dismissal on merits operated as an estoppel against relitigation, and the subsequent complaint and related orders were quashed with the petition disposed of.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
