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...
Direction of CIT(A) u/s 150 to take remedial action u/s 148 - Section 150(2) provides that direction shall not apply to an assessment year which was the subject matter of the appeal and limiting was already expired - as per section 149(1)(b), notice u/s 148 could have issued by the end of assessment year 2015-16 which had already elapsed - non est direction
Direction of CIT(A) u/s 150 to take remedial action u/s 148 - Section 150(2) provides that direction shall not apply to an assessment year which was the subject matter of the appeal and limiting was already expired - as per section 149(1)(b), notice u/s 148 could have issued by the end of assessment year 2015-16 which had already elapsed - non est direction
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