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...
Advance Ruling Authority declined jurisdiction to rule on the manner of claiming refund of accumulated input tax credit under the inverted duty structure and on refunds asserted as 'any other ground', holding that questions of quantification and sanction of refund fall within refund administration and are not among the categories listed under section 97(2). Applying section 95(a) read with section 97(2), the Authority found the application outside its statutory scope and rejected it as inadmissible, refusing to entertain advance ruling on refund quantification or sanction.
Advance Ruling Authority declined jurisdiction to rule on the manner of claiming refund of accumulated input tax credit under the inverted duty structure and on refunds asserted as 'any other ground', holding that questions of quantification and sanction of refund fall within refund administration and are not among the categories listed under section 97(2). Applying section 95(a) read with section 97(2), the Authority found the application outside its statutory scope and rejected it as inadmissible, refusing to entertain advance ruling on refund quantification or sanction.
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