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 - the sole reason for completing the scrutiny assessment was suspicious LTCG earned by assessee based on information received from Investigation Wing, it could not be believed that A.O. would not have gone through the material available - non discussion the details in the assessment order would not give right to the Ld. Pr. CIT to hold that no investigation or enquiry was made - A.O. has taken one of permissible view - no revision
Revision u/s 263 - the sole reason for completing the scrutiny assessment was suspicious LTCG earned by assessee based on information received from Investigation Wing, it could not be believed that A.O. would not have gone through the material available - non discussion the details in the assessment order would not give right to the Ld. Pr. CIT to hold that no investigation or enquiry was made - A.O. has taken one of permissible view - no revision
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