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...
Garnishee notice directing provisional attachment of the petitioner's bank account was ordered withdrawn because the revenue authority failed to consider the petitioner's prior submissions and offered documents; immediate freezing was unjustified absent findings of deliberate evasion. The petitioner must submit requisite documents within ten days, and the department must examine them, invite clarification or hearing if needed, and decide the recovery question on merits within one month of submission; all contentions remain open pending that reconsideration.
Garnishee notice directing provisional attachment of the petitioner's bank account was ordered withdrawn because the revenue authority failed to consider the petitioner's prior submissions and offered documents; immediate freezing was unjustified absent findings of deliberate evasion. The petitioner must submit requisite documents within ten days, and the department must examine them, invite clarification or hearing if needed, and decide the recovery question on merits within one month of submission; all contentions remain open pending that reconsideration.
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