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...
Notice of re-assessment u/s 148 - territorial jurisdiction of High Court - writ filed in Bombay whereas notice issued by AO in Hyderabad - any challenge to the orders of AO, CIT(A) or the Tribunal would lie before the High Court of Telangana - In the context of challenge to the notice of reassessment, this Court would apply the decisions of Bombay HC which would be wholly undesirable - petition is not entertained with liberty to move the appropriate HC
Notice of re-assessment u/s 148 - territorial jurisdiction of High Court - writ filed in Bombay whereas notice issued by AO in Hyderabad - any challenge to the orders of AO, CIT(A) or the Tribunal would lie before the High Court of Telangana - In the context of challenge to the notice of reassessment, this Court would apply the decisions of Bombay HC which would be wholly undesirable - petition is not entertained with liberty to move the appropriate HC
Note: It is a system-generated summary and is for quick reference only.