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...
Clubbing of tax periods in a single Section 74 show cause notice is impermissible because the CGST statutory scheme treats each financial year as a distinct tax period with separate limitation and procedural rights; aggregating years conflates distinct limitation dates and denies year wise rights, and allegations of fraudulent input tax credit do not authorise consolidation. Applying that principle, the court quashed the consolidated notice covering multiple financial years but permitted respondents liberty to reissue notices strictly year wise in accordance with the statutory scheme and to revive proceedings if higher forum decisions permit.
Clubbing of tax periods in a single Section 74 show cause notice is impermissible because the CGST statutory scheme treats each financial year as a distinct tax period with separate limitation and procedural rights; aggregating years conflates distinct limitation dates and denies year wise rights, and allegations of fraudulent input tax credit do not authorise consolidation. Applying that principle, the court quashed the consolidated notice covering multiple financial years but permitted respondents liberty to reissue notices strictly year wise in accordance with the statutory scheme and to revive proceedings if higher forum decisions permit.
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