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...
IGST on imported goods falls within the customs assessment framework, so tariff classification, valuation, exemption and tax recovery are to be handled by customs authorities; GST officers cannot assess or recover such IGST, and the impugned notice on that issue was set aside. Cross-empowerment under GST operates only where the taxpayer is administratively allotted to the State and the officer is the proper officer; as the taxpayer was allotted to Central jurisdiction, the State tax officer lacked jurisdiction. A circular already struck down by a High Court was treated as inoperative nationwide without fresh invalidation. The notice also failed because it sought to cover multiple years in one show cause notice, and was set aside on that ground as well.
IGST on imported goods falls within the customs assessment framework, so tariff classification, valuation, exemption and tax recovery are to be handled by customs authorities; GST officers cannot assess or recover such IGST, and the impugned notice on that issue was set aside. Cross-empowerment under GST operates only where the taxpayer is administratively allotted to the State and the officer is the proper officer; as the taxpayer was allotted to Central jurisdiction, the State tax officer lacked jurisdiction. A circular already struck down by a High Court was treated as inoperative nationwide without fresh invalidation. The notice also failed because it sought to cover multiple years in one show cause notice, and was set aside on that ground as well.
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