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...
Reassessment u/s 147 - in statement name of the assessee also found mentioned in the list of beneficiaries of bogus accommodation entries - information received by the AO from DGIT(inv.) is tangible incriminating information coming into possession, which has live link with formation of prima facie belief that income of the assessee has escaped assessment - uphold the reopening of the assessment
Reassessment u/s 147 - in statement name of the assessee also found mentioned in the list of beneficiaries of bogus accommodation entries - information received by the AO from DGIT(inv.) is tangible incriminating information coming into possession, which has live link with formation of prima facie belief that income of the assessee has escaped assessment - uphold the reopening of the assessment
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