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...
Validity of SCN issued after undue delay - there is no prescribed period of limitation for completing an assessment, it does not mean that the power can be exercised at any time, it had to be exercised within a reasonable period - the delay of over nine years or over five years in issuing the SCNs have not been satisfactorily explained - SCN quashed
Validity of SCN issued after undue delay - there is no prescribed period of limitation for completing an assessment, it does not mean that the power can be exercised at any time, it had to be exercised within a reasonable period - the delay of over nine years or over five years in issuing the SCNs have not been satisfactorily explained - SCN quashed
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