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...
Reassessment following a completed scrutiny assessment was initiated on alleged inflation of Special Economic Zone export profits through non-payment of interest on partners' capital and below-market gold purchases from a sister concern. Relevant transaction particulars had been available during the original assessment, while the amended partnership deed-specifically brought to the Assessing Officer's attention-had rendered the interest-payment clause inoperative. The reopening nevertheless relied on the original deed. Objections concerning the rate and fineness of gold were also not addressed. The reassessment notice and the order rejecting objections were quashed, and the writ petition succeeded.
Reassessment following a completed scrutiny assessment was initiated on alleged inflation of Special Economic Zone export profits through non-payment of interest on partners' capital and below-market gold purchases from a sister concern. Relevant transaction particulars had been available during the original assessment, while the amended partnership deed-specifically brought to the Assessing Officer's attention-had rendered the interest-payment clause inoperative. The reopening nevertheless relied on the original deed. Objections concerning the rate and fineness of gold were also not addressed. The reassessment notice and the order rejecting objections were quashed, and the writ petition succeeded.
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