Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
Reassessment beyond three years required the recorded reasons to show that the alleged escaped income was represented by an asset, expenditure, or entry in the books; absent that jurisdictional nexus, the notices and reassessment orders for AYs 2017-18 to 2019-20 were quashed. Material brought by a third person in response to summons during search could not be treated as search-seizure material to sustain notices under the search deeming fiction, so those notices were also invalid. The Tribunal further held that search information must relate to the relevant AY, and the absence of that link vitiated the notices for AYs 2020-21 to 2022-23. On merits, the wholesale two-zeroes theory on all cash entries was rejected, but 16% profit on recomputed unaccounted receipts was sustained.
Reassessment beyond three years required the recorded reasons to show that the alleged escaped income was represented by an asset, expenditure, or entry in the books; absent that jurisdictional nexus, the notices and reassessment orders for AYs 2017-18 to 2019-20 were quashed. Material brought by a third person in response to summons during search could not be treated as search-seizure material to sustain notices under the search deeming fiction, so those notices were also invalid. The Tribunal further held that search information must relate to the relevant AY, and the absence of that link vitiated the notices for AYs 2020-21 to 2022-23. On merits, the wholesale two-zeroes theory on all cash entries was rejected, but 16% profit on recomputed unaccounted receipts was sustained.
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