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...
When a statutory appellate forum is non-functional an aggrieved person may seek writ relief to avoid being remediless, but such relief cannot displace or relax statutory conditions attached to the statutory appeal. The note emphasises that where the appellate tribunal has been made functional and filing windows extended, disputes should be adjudicated by the designated forum. The pre-deposit condition requiring payment of the admitted amount and an additional portion of disputed tax remains binding and must be complied with before the appeal is entertained by the tribunal within the prescribed timeline.
When a statutory appellate forum is non-functional an aggrieved person may seek writ relief to avoid being remediless, but such relief cannot displace or relax statutory conditions attached to the statutory appeal. The note emphasises that where the appellate tribunal has been made functional and filing windows extended, disputes should be adjudicated by the designated forum. The pre-deposit condition requiring payment of the admitted amount and an additional portion of disputed tax remains binding and must be complied with before the appeal is entertained by the tribunal within the prescribed timeline.
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