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...
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - Incentive for quality orders - such guidelines have a propensity to influence the CIT(A) and be tempted to pass an order in a particular manner so as to achieve a greater target of disposal - transgresses in the CIT(A)'s exercise of discretionary quasi-judicial powers - would not stand the test of law - this portion of the impugned Action Plan of CBDT is set aside
Disposal of appeal by CIT(A) - "Central Action Plan” prepared by CBDT - Incentive for quality orders - such guidelines have a propensity to influence the CIT(A) and be tempted to pass an order in a particular manner so as to achieve a greater target of disposal - transgresses in the CIT(A)'s exercise of discretionary quasi-judicial powers - would not stand the test of law - this portion of the impugned Action Plan of CBDT is set aside
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