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 - reopening based on dictation/instance of the investigation wing - the authority, indicating the information was of the equal rank and not a higher authority - the AO is merely advised to take any remedial actions in accordance with the law - no instance of or at the dictate of higher authorities - reopening upheld
Reassessment u/s 147 - reopening based on dictation/instance of the investigation wing - the authority, indicating the information was of the equal rank and not a higher authority - the AO is merely advised to take any remedial actions in accordance with the law - no instance of or at the dictate of higher authorities - reopening upheld
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