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 - Gain on cancellation of forwarding contract - characterization of income - Revenue may be correct in contending that, the Assessing Officer had not carried out detailed enquiries that by itself would not be sufficient to enable the Commissioner to exercise revisional power if based on materials already on record come to the same conclusion that amount is capital nature and not taxable.
Revision u/s 263 - Gain on cancellation of forwarding contract - characterization of income - Revenue may be correct in contending that, the Assessing Officer had not carried out detailed enquiries that by itself would not be sufficient to enable the Commissioner to exercise revisional power if based on materials already on record come to the same conclusion that amount is capital nature and not taxable.
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