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...
Prior to the amendment of section 3(12) of the Customs Tariff Act effective from 16.08.2024, the Customs Act provisions on interest, offences and penalties did not apply to IGST leviable under section 3(7). Applying the Bombay HC rulings in A.R. Sulphonates and Mahindra & Mahindra, the Tribunal held that interest, redemption fine and penalty for the period governed by the unamended provision were without authority of law. The impugned order was therefore set aside to that extent. The confirmation and recovery of IGST itself was not disturbed and was upheld.
Prior to the amendment of section 3(12) of the Customs Tariff Act effective from 16.08.2024, the Customs Act provisions on interest, offences and penalties did not apply to IGST leviable under section 3(7). Applying the Bombay HC rulings in A.R. Sulphonates and Mahindra & Mahindra, the Tribunal held that interest, redemption fine and penalty for the period governed by the unamended provision were without authority of law. The impugned order was therefore set aside to that extent. The confirmation and recovery of IGST itself was not disturbed and was upheld.
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