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...
In a limited scrutiny assessment selected through CASS, the Assessing Officer is confined to the specific issues for which scrutiny was initiated. Enquiry into matters outside those issues is permissible only after conversion into complete scrutiny with the prescribed approval. Because the addition was made beyond the selected scrutiny scope and no valid conversion was shown, the Tribunal held that the assessment had travelled beyond jurisdiction and the addition was unsustainable. The assessee's appeal was allowed.
In a limited scrutiny assessment selected through CASS, the Assessing Officer is confined to the specific issues for which scrutiny was initiated. Enquiry into matters outside those issues is permissible only after conversion into complete scrutiny with the prescribed approval. Because the addition was made beyond the selected scrutiny scope and no valid conversion was shown, the Tribunal held that the assessment had travelled beyond jurisdiction and the addition was unsustainable. The assessee's appeal was allowed.
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