Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
Revision u/s 263 - change of opinion - in proceedings u/s 147 assessee contended that the transfer price was based on the individual assets and liabilities of the undertaking transferred and the sale would not qualify as “Slump Sale” as per Section 2(42C) - this explanation of the Assessee was accepted by the AO - for the very same reasons, the CIT has invoked the power u/s 263 - not permissible
Revision u/s 263 - change of opinion - in proceedings u/s 147 assessee contended that the transfer price was based on the individual assets and liabilities of the undertaking transferred and the sale would not qualify as “Slump Sale” as per Section 2(42C) - this explanation of the Assessee was accepted by the AO - for the very same reasons, the CIT has invoked the power u/s 263 - not permissible
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