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...
Enhancement by CITA) to book profit computation u/s.115JB - provisions were sought to be added u/s 115JB only pursuant to an amendment by the FA 2008 w.e.f 01/04/2001 - Hence, on the date of passing of order u/s.143(3) on 31/01/2006, the ld. AO could not have added the same - what could not have been done by the ld. AO as per law prevailing at that time, the ld. CIT(A) could not do by exercising enhancement powers
Enhancement by CITA) to book profit computation u/s.115JB - provisions were sought to be added u/s 115JB only pursuant to an amendment by the FA 2008 w.e.f 01/04/2001 - Hence, on the date of passing of order u/s.143(3) on 31/01/2006, the ld. AO could not have added the same - what could not have been done by the ld. AO as per law prevailing at that time, the ld. CIT(A) could not do by exercising enhancement powers
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