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...
Reopening of assessment - Revenue has received cogent tangible material having live link/nexus with the reasons to believe that the income has escaped assessment, the return of income was originally processed and accepted u/s 143(1) and not u/s 143(3) r.w.s. 143(2) - case was re-opened within four years - Revenue has rightly invoked the provisions of section 147/148 - AT
Reopening of assessment - Revenue has received cogent tangible material having live link/nexus with the reasons to believe that the income has escaped assessment, the return of income was originally processed and accepted u/s 143(1) and not u/s 143(3) r.w.s. 143(2) - case was re-opened within four years - Revenue has rightly invoked the provisions of section 147/148 - AT
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