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...
A revised return that only claimed TDS credit did not require a fresh scrutiny notice where a notice under section 143(2) had already been issued on the original return and no prejudice was shown from the absence of a second notice. For unexplained cash deposits, amounts already taxed in an earlier year could not be assessed again as the same income, and further relief was allowed having regard to the assessee's age, deposit pattern and past income history; only the unexplained balance remained taxable under section 69A. The higher rate under section 115BBE was held prospective, so the surviving addition was to be taxed at the pre-amendment rate.
A revised return that only claimed TDS credit did not require a fresh scrutiny notice where a notice under section 143(2) had already been issued on the original return and no prejudice was shown from the absence of a second notice. For unexplained cash deposits, amounts already taxed in an earlier year could not be assessed again as the same income, and further relief was allowed having regard to the assessee's age, deposit pattern and past income history; only the unexplained balance remained taxable under section 69A. The higher rate under section 115BBE was held prospective, so the surviving addition was to be taxed at the pre-amendment rate.
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