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...
Transitional input tax credit under Section 140 must be examined within its own confined jurisdiction, and issues falling within MVAT proceedings cannot be imported without a proper Section 140 analysis. The appellate authority's findings were vague, non-speaking and did not show a legally structured consideration of the limited credit issue. The High Court therefore set aside the appellate order and remanded the matter for fresh, independent adjudication on transitional input tax credit after hearing both sides, with all contentions left open.
Transitional input tax credit under Section 140 must be examined within its own confined jurisdiction, and issues falling within MVAT proceedings cannot be imported without a proper Section 140 analysis. The appellate authority's findings were vague, non-speaking and did not show a legally structured consideration of the limited credit issue. The High Court therefore set aside the appellate order and remanded the matter for fresh, independent adjudication on transitional input tax credit after hearing both sides, with all contentions left open.
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