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...
Writ challenges to show-cause and pre-intimation notices blocking input tax credit were held premature where the disputes turned on individual facts and the CGST Act and Rules provided a complete code. The Court declined to examine the merits of the proposed ITC action or the constitutional validity of Section 16(2)(c) at this stage, finding that such issues required case-specific adjudication after replies and objections were considered. Petitioners were permitted to respond to the notices, and the statutory authorities were directed to decide the matters in accordance with law, while keeping all contentions open.
Writ challenges to show-cause and pre-intimation notices blocking input tax credit were held premature where the disputes turned on individual facts and the CGST Act and Rules provided a complete code. The Court declined to examine the merits of the proposed ITC action or the constitutional validity of Section 16(2)(c) at this stage, finding that such issues required case-specific adjudication after replies and objections were considered. Petitioners were permitted to respond to the notices, and the statutory authorities were directed to decide the matters in accordance with law, while keeping all contentions open.
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