Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
Intellectual Property Right Services - the transfer of right is absolutely in terms of the agreement, therefore, proviso Section 65(55)b) of the act are not applicable - AT
Intellectual Property Right Services - the transfer of right is absolutely in terms of the agreement, therefore, proviso Section 65(55)b) of the act are not applicable - AT
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