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 264(4) does not bar revision merely because the statutory period for filing an appeal has expired. Where no appeal or condonation application is pending and waiver of appeal is not relevant, the Revisional Authority should entertain the revision on merits. Refusal on the premise that the revision is non-maintainable is erroneous, and merits observations founded on that premise cannot stand. The rejection was set aside, with the revision restored for fresh adjudication on merits; all substantive contentions remain open.
Section 264(4) does not bar revision merely because the statutory period for filing an appeal has expired. Where no appeal or condonation application is pending and waiver of appeal is not relevant, the Revisional Authority should entertain the revision on merits. Refusal on the premise that the revision is non-maintainable is erroneous, and merits observations founded on that premise cannot stand. The rejection was set aside, with the revision restored for fresh adjudication on merits; all substantive contentions remain open.
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