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 - disallowance u/s 40(a)(ia) - CIT has not correctly interpreted the provisions of sec.194C(2) nor consider the law amended in sec.40(a)(ia) held to be applicable retrospectively - CIT also failed to verify and conduct the minimal enquiry about non-deduction of TDS and deposit of TDS before the due date for filing the return of income - Revision order set aside.
Revision u/s 263 - disallowance u/s 40(a)(ia) - CIT has not correctly interpreted the provisions of sec.194C(2) nor consider the law amended in sec.40(a)(ia) held to be applicable retrospectively - CIT also failed to verify and conduct the minimal enquiry about non-deduction of TDS and deposit of TDS before the due date for filing the return of income - Revision order set aside.
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