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...
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
Section 153C jurisdiction is treated as constructively satisfied where the same Assessing Officer handles the searched person and the other person, so physical handover of seized material is not essential once the officer applies his mind. One consolidated satisfaction note can cover the six-year block under sections 153C and 153A, and an Investigation Wing trigger is not fatal by itself. On limitation, the assessments were time-barred because the relevant date, whether taken as the search, constructive handover, conclusion of Settlement Commission proceedings, or recording of satisfaction, placed the proceedings outside the statutory period. Additions based on uncorroborated third-party excel sheets were unsustainable where identity was doubtful and cross-examination was denied.
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