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...
An admitted acknowledgment of liability can give rise to a fresh starting point of limitation, and the court-closure rule applies when the last day falls on a weekend and filing is made on the reopening day. The tribunal also clarified that the default-proof requirement is not confined to information-utility records: prima facie disclosure of debt and default may be shown through balance-sheet admissions and the debtor's written statement. A new limitation plea cannot be raised for the first time in written submissions after arguments, because written submissions are not pleadings.
An admitted acknowledgment of liability can give rise to a fresh starting point of limitation, and the court-closure rule applies when the last day falls on a weekend and filing is made on the reopening day. The tribunal also clarified that the default-proof requirement is not confined to information-utility records: prima facie disclosure of debt and default may be shown through balance-sheet admissions and the debtor's written statement. A new limitation plea cannot be raised for the first time in written submissions after arguments, because written submissions are not pleadings.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
