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...
Revision u/s 263 - Period of limitation - if the issue on which the proceedings u/s 263 is initiated is not a subject matter of the assessment order passed u/s 143(3) r/w 147, then the limitation period has to be reckoned from the original assessment order passed u/s 143(3) or if the return of income was processed u/s 143(1), then from the date of intimation u/s 143(1)
Revision u/s 263 - Period of limitation - if the issue on which the proceedings u/s 263 is initiated is not a subject matter of the assessment order passed u/s 143(3) r/w 147, then the limitation period has to be reckoned from the original assessment order passed u/s 143(3) or if the return of income was processed u/s 143(1), then from the date of intimation u/s 143(1)
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