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...
HC held that assessment orders passed under Section 62 for non-filing of returns stood deemed withdrawn once the taxpayers later filed the returns for the relevant periods along with tax, interest and late fee. The statutory consequence under Section 62(2) barred further recovery on the basis of those assessment orders. Any amount already recovered under the withdrawn orders was directed to be adjusted against the taxpayers' outstanding tax dues.
HC held that assessment orders passed under Section 62 for non-filing of returns stood deemed withdrawn once the taxpayers later filed the returns for the relevant periods along with tax, interest and late fee. The statutory consequence under Section 62(2) barred further recovery on the basis of those assessment orders. Any amount already recovered under the withdrawn orders was directed to be adjusted against the taxpayers' outstanding tax dues.
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