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...
Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
Additions based on documents seized in the case of another person must be brought within the reassessment framework under Explanation 2 to section 148, after recording the prescribed satisfaction and obtaining statutory approval; they cannot be made in a regular assessment under section 143(3). The ITAT held that the Assessing Officer's use of third-party search material without following that mandatory procedure rendered the assessment invalid. The assessment order was therefore quashed, and the remaining grounds became academic.
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