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...
Eligibility to act as an authorised representative is distinct from eligibility for registration as an Income Tax Practitioner. Section 515 read with Rule 252 governs who may appear as an authorised representative, while Rules 255 to 257 govern entry in the register and grant of a certificate of registration. The one-year practice requirement in Rule 257 applies only to registration; it does not restrict the separate right to appear as a representative. As the applicant had not completed one year's practice on the date of application, and the rule itself was not challenged, the return of the application was held lawful and a fresh application was permitted after completion of the prescribed period.
Eligibility to act as an authorised representative is distinct from eligibility for registration as an Income Tax Practitioner. Section 515 read with Rule 252 governs who may appear as an authorised representative, while Rules 255 to 257 govern entry in the register and grant of a certificate of registration. The one-year practice requirement in Rule 257 applies only to registration; it does not restrict the separate right to appear as a representative. As the applicant had not completed one year's practice on the date of application, and the rule itself was not challenged, the return of the application was held lawful and a fresh application was permitted after completion of the prescribed period.
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