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...
Inclusion of AY in which search was conducted into the period of 6 assessment years - recording of satisfaction during the next year - assessment for assessment year 2008-09 should have been completed u/s 153A read with 153C and not as regular assessment u/s 143(3), by treating the A.Y. 2008-09 as year of search. - AT
Inclusion of AY in which search was conducted into the period of 6 assessment years - recording of satisfaction during the next year - assessment for assessment year 2008-09 should have been completed u/s 153A read with 153C and not as regular assessment u/s 143(3), by treating the A.Y. 2008-09 as year of search. - AT
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