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 - lack of enquiry - Deemed dividend u/s 2(22)(e) - AO had not only made the enquiry or verification to ascertain the applicability of section 2(22)(e) to the loan amounts received by the assessee from the other group companies, but a conscious decision was also taken by him in view the legal position as propounded by the Jurisdictional HC - revision set aside
Revision u/s 263 - lack of enquiry - Deemed dividend u/s 2(22)(e) - AO had not only made the enquiry or verification to ascertain the applicability of section 2(22)(e) to the loan amounts received by the assessee from the other group companies, but a conscious decision was also taken by him in view the legal position as propounded by the Jurisdictional HC - revision set aside
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