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...
Provident fund claims in CIRP must rest on crystallised statutory dues; an internal communication or tentative computation cannot by itself establish an admissible claim. The Appellate Tribunal held that, where the provident fund liability had not been assessed and crystallised at the relevant time, the claim could not be sustained on the basis of a provisional document alone. The rejection of the application was therefore upheld and the appeal dismissed.
Provident fund claims in CIRP must rest on crystallised statutory dues; an internal communication or tentative computation cannot by itself establish an admissible claim. The Appellate Tribunal held that, where the provident fund liability had not been assessed and crystallised at the relevant time, the claim could not be sustained on the basis of a provisional document alone. The rejection of the application was therefore upheld and the appeal dismissed.
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