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...
Validity of proceedings u/s 153A - the date of receipt of the documents is 13.12.2006, which relates to the AY 2007-2008 - the assessment year in which the documents are received by the AO of the "other person‟ is NOT required to be made u/s 153C of the Act - AT
Validity of proceedings u/s 153A - the date of receipt of the documents is 13.12.2006, which relates to the AY 2007-2008 - the assessment year in which the documents are received by the AO of the "other person‟ is NOT required to be made u/s 153C of the Act - AT
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