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...
A High Court decision on tax litigation reiterated that condonation of delay depends only on sufficient cause, and prolonged administrative inaction, unexplained gaps and file movement without justification do not warrant indulgence; the State is held to the same diligence standard as any litigant. It also reaffirmed that review jurisdiction is narrow and cannot be used for rehearing unless there is an apparent error or comparable ground. On the tax issue, the Court applied strict construction of the notification and held that denatured spirit is distinct from ethyl alcohol; because the 30.03.2002 notification covered only rectified spirit, neutral spirit and ethyl alcohol, it did not impose entry tax on denatured spirit.
A High Court decision on tax litigation reiterated that condonation of delay depends only on sufficient cause, and prolonged administrative inaction, unexplained gaps and file movement without justification do not warrant indulgence; the State is held to the same diligence standard as any litigant. It also reaffirmed that review jurisdiction is narrow and cannot be used for rehearing unless there is an apparent error or comparable ground. On the tax issue, the Court applied strict construction of the notification and held that denatured spirit is distinct from ethyl alcohol; because the 30.03.2002 notification covered only rectified spirit, neutral spirit and ethyl alcohol, it did not impose entry tax on denatured spirit.
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