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 a best judgment assessment under Section 62 cannot stand unless the statutory notice preceding the assessment is proved to have been served in a mode recognised by Section 169. A mere recital in the assessment order that notice was issued was insufficient, and the respondents produced no material showing valid service before completion of the assessments. In the absence of proof of service of the mandatory notice, the impugned assessment orders were quashed and the matter was left open for fresh consideration after due notice, if warranted.
HC held that a best judgment assessment under Section 62 cannot stand unless the statutory notice preceding the assessment is proved to have been served in a mode recognised by Section 169. A mere recital in the assessment order that notice was issued was insufficient, and the respondents produced no material showing valid service before completion of the assessments. In the absence of proof of service of the mandatory notice, the impugned assessment orders were quashed and the matter was left open for fresh consideration after due notice, if warranted.
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