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...
Assessment u/s 153A - there are contradictory findings regarding the action taken by the Revenue i.e. Survey and Search, and further in the absence of any documentary proof submitted by the Revenue to prove that the search warrant was issued in the name of the assessee the assessment made u/s. 143(3) r.w.s. 153A is bad in law and void ab-initio.
Assessment u/s 153A - there are contradictory findings regarding the action taken by the Revenue i.e. Survey and Search, and further in the absence of any documentary proof submitted by the Revenue to prove that the search warrant was issued in the name of the assessee the assessment made u/s. 143(3) r.w.s. 153A is bad in law and void ab-initio.
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