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...
High Court considered mandatory pre-deposit as a condition for entertaining a statutory appeal and found petitioner failed to comply despite personal hearings and specific directions, reflecting adversely on petitioner's conduct; combined with an unexplained and unreasonable delay in filing a writ challenging the appellate order, the court applied the doctrine that writs must be filed within a reasonable time and declined interference. Reliance was placed on relevant Supreme Court authorities regarding delay and laches. Writ petition dismissed for lack of merit due to non-deposit and inordinate delay.
High Court considered mandatory pre-deposit as a condition for entertaining a statutory appeal and found petitioner failed to comply despite personal hearings and specific directions, reflecting adversely on petitioner's conduct; combined with an unexplained and unreasonable delay in filing a writ challenging the appellate order, the court applied the doctrine that writs must be filed within a reasonable time and declined interference. Reliance was placed on relevant Supreme Court authorities regarding delay and laches. Writ petition dismissed for lack of merit due to non-deposit and inordinate delay.
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