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...
For reassessment notices issued more than three years after the end of the relevant assessment year, prior approval from the higher specified authority under section 151(ii) is a jurisdictional precondition. Approval from the Principal Commissioner under section 151(i) is insufficient where section 151(ii) applies. Applying this requirement to assessment year 2018-19, the section 148 notice and reassessment under sections 147 and 144B were void ab initio because the required approval was not obtained. The appeal was allowed after condoning delay, and the reassessment was quashed.
For reassessment notices issued more than three years after the end of the relevant assessment year, prior approval from the higher specified authority under section 151(ii) is a jurisdictional precondition. Approval from the Principal Commissioner under section 151(i) is insufficient where section 151(ii) applies. Applying this requirement to assessment year 2018-19, the section 148 notice and reassessment under sections 147 and 144B were void ab initio because the required approval was not obtained. The appeal was allowed after condoning delay, and the reassessment was quashed.
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