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...
Absence of a signature on sanction under the reassessment provisions was treated as a challenge requiring reconsideration after the retrospective insertion of Section 292BC introduced a new legal dimension. Because the assessee had not been given an opportunity in the writ proceedings to address the effect of that retrospective provision, the court restored the writ petition for fresh consideration and left all contentions open. No opinion was expressed on the merits of the reassessment challenge, and the matter was remitted so both sides could address the applicability of the new provision before a final decision.
Absence of a signature on sanction under the reassessment provisions was treated as a challenge requiring reconsideration after the retrospective insertion of Section 292BC introduced a new legal dimension. Because the assessee had not been given an opportunity in the writ proceedings to address the effect of that retrospective provision, the court restored the writ petition for fresh consideration and left all contentions open. No opinion was expressed on the merits of the reassessment challenge, and the matter was remitted so both sides could address the applicability of the new provision before a final decision.
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