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...
Non-compliance with the pre-deposit requirement under section 107(6) was treated as a curable procedural defect where the taxpayer had deposited the amount in the electronic cash ledger and shown an intention to comply. The High Court held that the appeal was dismissed solely for alleged non-compliance, not on merits, and that natural justice required the Appellate Authority to point out the defect and allow reasonable time to cure it before rejecting the appeal. The order was quashed and the matter remanded for consideration on merits after the pre-deposit issue is rectified.
Non-compliance with the pre-deposit requirement under section 107(6) was treated as a curable procedural defect where the taxpayer had deposited the amount in the electronic cash ledger and shown an intention to comply. The High Court held that the appeal was dismissed solely for alleged non-compliance, not on merits, and that natural justice required the Appellate Authority to point out the defect and allow reasonable time to cure it before rejecting the appeal. The order was quashed and the matter remanded for consideration on merits after the pre-deposit issue is rectified.
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