Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Section 143(1) processing may continue after issuance of a scrutiny notice under section 143(2) for returns from assessment years commencing on or after 1 April 2017. The note explains that merger is issue-specific: only matters actually examined and decided in subsequent scrutiny merge, so unexamined processing adjustments remain separate matters arising from the intimation. It also states that an Assessing Officer need not revisit CPC adjustments merely because scrutiny follows. Cross-charged ESOP costs reimbursed by an Indian subsidiary to its foreign parent are described as employee compensation incurred wholly and exclusively for business, rather than capital expenditure, where the subsidiary neither issues shares nor acquires a capital asset.
Section 143(1) processing may continue after issuance of a scrutiny notice under section 143(2) for returns from assessment years commencing on or after 1 April 2017. The note explains that merger is issue-specific: only matters actually examined and decided in subsequent scrutiny merge, so unexamined processing adjustments remain separate matters arising from the intimation. It also states that an Assessing Officer need not revisit CPC adjustments merely because scrutiny follows. Cross-charged ESOP costs reimbursed by an Indian subsidiary to its foreign parent are described as employee compensation incurred wholly and exclusively for business, rather than capital expenditure, where the subsidiary neither issues shares nor acquires a capital asset.
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