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...
Retrospective substitution of the proviso to section 50(1) means interest on delayed GST payment is chargeable only on the portion discharged through the electronic cash ledger, i.e. the net cash liability. The existing demand therefore had to be tested against the amended legal position, and the authorities were required to reconsider the matter afresh after giving the taxpayer an opportunity of hearing. The petition was disposed of by remitting the issue for fresh decision under the amended proviso.
Retrospective substitution of the proviso to section 50(1) means interest on delayed GST payment is chargeable only on the portion discharged through the electronic cash ledger, i.e. the net cash liability. The existing demand therefore had to be tested against the amended legal position, and the authorities were required to reconsider the matter afresh after giving the taxpayer an opportunity of hearing. The petition was disposed of by remitting the issue for fresh decision under the amended proviso.
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