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...
Assignment of leasehold rights and whether it constitutes a taxable supply is the central issue; the High Court noted pending Supreme Court appeals on whether such assignments amount to 'transfer of land' or a taxable supply and therefore extended interim protection. The Court stayed recovery under impugned orders and stayed adjudication of outstanding show cause notices until final disposal, directed issuance of notice to the Attorney General where constitutional validity of CGST provisions is challenged, and permitted filing of replies with liberty to apply further, while awaiting the Supreme Court's determination.
Assignment of leasehold rights and whether it constitutes a taxable supply is the central issue; the High Court noted pending Supreme Court appeals on whether such assignments amount to 'transfer of land' or a taxable supply and therefore extended interim protection. The Court stayed recovery under impugned orders and stayed adjudication of outstanding show cause notices until final disposal, directed issuance of notice to the Attorney General where constitutional validity of CGST provisions is challenged, and permitted filing of replies with liberty to apply further, while awaiting the Supreme Court's determination.
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