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...
Territorial jurisdiction defect rendered the assessment invalid where the assessee's case remained with the Mumbai Assessing Officer and no transfer order for the relevant year was shown. The Tribunal noted that the assessee had been assessed by Mumbai in the preceding and succeeding years, and that the Delhi Assessing Officer therefore lacked authority to frame the order. It further held that the bar on belated objections to jurisdiction did not cure an inherent lack of jurisdiction, so the impugned orders were set aside and the other grounds were left academic.
Territorial jurisdiction defect rendered the assessment invalid where the assessee's case remained with the Mumbai Assessing Officer and no transfer order for the relevant year was shown. The Tribunal noted that the assessee had been assessed by Mumbai in the preceding and succeeding years, and that the Delhi Assessing Officer therefore lacked authority to frame the order. It further held that the bar on belated objections to jurisdiction did not cure an inherent lack of jurisdiction, so the impugned orders were set aside and the other grounds were left academic.
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