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...
Availability of an efficacious alternative statutory remedy precluded writ relief: the High Court declined to examine merits because the petitioner had not availed the statutory appeal under Section 107 of the CGST Act read with Rule 109A. Complaints of non-supply of relied documents, defective service and service dates of summons, alleged non-consideration of replies and non-application of mind were held to arise from the adjudicatory record and fall within the scope of the statutory appellate forum; petition dismissed with liberty to pursue the prescribed appeal.
Availability of an efficacious alternative statutory remedy precluded writ relief: the High Court declined to examine merits because the petitioner had not availed the statutory appeal under Section 107 of the CGST Act read with Rule 109A. Complaints of non-supply of relied documents, defective service and service dates of summons, alleged non-consideration of replies and non-application of mind were held to arise from the adjudicatory record and fall within the scope of the statutory appellate forum; petition dismissed with liberty to pursue the prescribed appeal.
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