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 ‘Note’ in Annual Reports on Software development projects and the various stages of software development placed by the assessee before the AO discloses all information on project - it is presumed that AO has examined the entitlement of deduction u/s 10A in all angles and withdrawal of the same based on the assessment order for AY 2007-08 is without application of mind and nothing but change of opinion, which tantamounts to review and is not permissible
Reassessment u/s 147 - In ‘Note’ in Annual Reports on Software development projects and the various stages of software development placed by the assessee before the AO discloses all information on project - it is presumed that AO has examined the entitlement of deduction u/s 10A in all angles and withdrawal of the same based on the assessment order for AY 2007-08 is without application of mind and nothing but change of opinion, which tantamounts to review and is not permissible
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