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 writ petition in a tax matter was held not maintainable where the adjudicating authority had considered the taxpayer's reply, written submissions, annexures, invoices, classification plea, exemption claim and valuation objections. The Court found no breach of natural justice because adequate opportunity of hearing had been given and the impugned order dealt with the material on record while partly confirming and partly dropping the demand. As the dispute involved detailed factual and legal examination, the petitioner was directed to pursue the statutory appellate remedy, where all grounds could be raised. The writ petition was dismissed, with liberty to file an appeal on complying with the statutory deposit requirement.
A writ petition in a tax matter was held not maintainable where the adjudicating authority had considered the taxpayer's reply, written submissions, annexures, invoices, classification plea, exemption claim and valuation objections. The Court found no breach of natural justice because adequate opportunity of hearing had been given and the impugned order dealt with the material on record while partly confirming and partly dropping the demand. As the dispute involved detailed factual and legal examination, the petitioner was directed to pursue the statutory appellate remedy, where all grounds could be raised. The writ petition was dismissed, with liberty to file an appeal on complying with the statutory deposit requirement.
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